582 1 IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA CASE NO. 00-5682-CI-11 2 3 4 DELL LIEBREICH, as Personal 5 Representative of the ESTATE OF LISA McPHERSON, 6 7 Plaintiff, 8 vs. VOLUME 5 9 CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, JANIS 10 JOHNSON, ALAIN KARTUZINSKI and DAVID HOUGHTON, D.D.S., 11 Defendants. 12 _______________________________________/ 13 14 15 PROCEEDINGS: Defendants' Omnibus Motion for Terminating Sanctions and Other Relief. 16 CONTENTS: Testimony of Jesse Prince. 17 DATE: July 9, 2002. Afternoon Session. 18 PLACE: Courtroom B, Judicial Building 19 St. Petersburg, Florida. 20 BEFORE: Honorable Susan F. Schaeffer, Circuit Judge. 21 REPORTED BY: Lynne J. Ide, RMR. 22 Deputy Official eCourt Reporter, Sixth Judicial Circuit of Florida. 23 24 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 583 1 APPEARANCES: 2 MR. KENNAN G. DANDAR 3 DANDAR & DANDAR 5340 West Kennedy Blvd., Suite 201 4 Tampa, FL 33602 Attorney for Plaintiff. 5 6 MR. LUKE CHARLES LIROT LUKE CHARLES LIROT, PA 7 112 N East Street, Street, Suite B Tampa, FL 33602-4108 8 Attorney for Plaintiff 9 MR. KENDRICK MOXON 10 MOXON & KOBRIN 1100 Cleveland Street, Suite 900 11 Clearwater, FL 33755 Attorney for Church of Scientology Flag Service 12 Organization. 13 MR. LEE FUGATE 14 MR. MORRIS WEINBERG, JR. ZUCKERMAN, SPAEDER 15 101 E. Kennedy Blvd, Suite 1200 Tampa, FL 33602-5147 16 Attorney for Church of Scientology Flag Service Organization. 17 18 MR. ERIC M. LIEBERMAN RABINOWITZ, BOUDIN, STANDARD 19 740 Broadway at Astor Place New York, NY 10003-9518 20 Attorney for Church of Scientology Flag Service Organization. 21 22 23 24 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 584 1 MR. STEPHEN J. WEIN Battaglia, Ross, Dicus & Wein, P.A. 2 980 Tyrone Boulevard St. Petersburg, Florida 33710 3 Counsel for Robert Minton. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 585 1 THE COURT: You may be seated. Okay, before we 2 begin, two questions. Have you decided when you 3 want the trial date, Mr. Dandar? 4 MR. DANDAR: September. 5 THE COURT: All right. Have you decided 6 whether or not you need Mr. Rosen? 7 MR. DANDAR: No, I don't need Mr. Rosen. 8 THE COURT: All right. Then I'm going to 9 assume that -- I will go ahead and enter an order 10 pro hac vice admitting Mr. Rosen, just in case. 11 He'll be admitted, just for this purpose. And I'll 12 let you have -- 13 MR. FUGATE: Should I prepare an order, Judge? 14 THE COURT: Do you mind? 15 MR. FUGATE: No. 16 THE COURT: Tell him to prepare an order, 17 whatever. 18 MR. FUGATE: I'll do it. 19 MR. DANDAR: So, Judge, since we will start 20 picking a jury for the trial in September, what 21 specific date would that be? 22 THE COURT: The second week in September. 23 Whatever that Monday is. 24 MR. DANDAR: All right. 25 THE COURT: You may proceed. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 586 1 MR. DANDAR: Thank you. 2 THE COURT: That, of course, assumes the motion 3 to dismiss is not granted. 4 MR. DANDAR: I understand. 5 THE COURT: Mr. Lirot, are you still of the 6 mind that if Mr. Dandar is removed as counsel, you 7 are prepared on that date? 8 MR. LIROT: Hope springs eternal, Judge. But 9 yes, Judge, I'll be prepared on that date if need 10 be. 11 THE COURT: All right. 12 BY MR. DANDAR: 13 Q Mr. Prince, what I was trying to do before the 14 lunch break was finish up on the meetings that you had with 15 Mr. Minton and Stacy Brooks. 16 A Okay. 17 Q I believe we left off with your meeting with them 18 when things got a little testy at the hotel for dinner. 19 A At the Radisson. 20 Q At the Radisson. In my -- your note attached to 21 your affidavit, you said you met with me before you met with 22 them that Sunday. So that was April 14th. 23 A Okay. 24 Q All right? So let's go from then on. What 25 happened after April 14th? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 587 1 A Mmm -- 2 THE COURT: I'm sorry, he met with you before 3 he met with them? 4 MR. DANDAR: That same day. That is where this 5 handwritten note -- 6 THE COURT: Right. For some reason, I thought 7 it was after. But it was before? 8 MR. DANDAR: On this particular day he met with 9 me at the mall with Mr. Lirot. And that was 10 April 14th. 11 THE COURT: In the afternoon? Then he went 12 there in the evening? 13 MR. DANDAR: Then he went there. 14 BY MR. DANDAR: 15 Q What happened after April 14th? 16 A Mmm, well, contact again -- and I think I 17 mentioned I had the one phone conversation with Mr. Minton 18 where I invited him over to my house. But they -- they 19 talked to me -- or got messages to me via my fiancee. They 20 would talk to her. And if anything happened -- we wouldn't 21 talk, we were not talking. 22 Q And what messages did you receive from Mr. Minton 23 and Ms. Brooks that way? 24 MR. WEINBERG: Objection. Hearsay, your Honor. 25 THE COURT: Hearsay. That would have to be Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 588 1 hearsay. I mean, that would have nothing to do with 2 Mr. Minton's state of mind or anything in this 3 proceeding, so you would have to, at the very least, 4 bring in the other person. 5 BY MR. DANDAR: 6 Q So you never talked with Mr. Minton or Ms. Brooks 7 since then directly, one-on-one? 8 A I talked with Mrs. Brooks. Mmm, she just told me 9 that everything was going to be fine, regardless of whether 10 or not I agreed to go with them or participate in activities 11 with them with Scientology. She just told me things were 12 going to be okay. 13 Q When did Ms. Brooks stop paying you your monthly 14 income? 15 A Either March or April. 16 Q And you said before that you went to Denis 17 deVlaming's office and spoke with him, and he couldn't help 18 you because of the conflict of interest. 19 Did you go to any law enforcement? 20 A Well, it's not entirely true to say that 21 Mr. DeVlaming couldn't help me. What Mr. DeVlaming did do 22 is refer me to his brother because, again, I wanted to 23 somehow get a federal law enforcement involved in this, 24 since my perception was that the criminal activity -- 25 conspiracy and criminal activity happened at least in New Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 589 1 York, New Hampshire and Clearwater. 2 Mmm, he said that he would talk with a federal 3 agent that he did know and get back with me. He -- I guess 4 maybe a day or so later, he had a conversation with the 5 federal agent, Mr. Douglas DeVlaming. And he told me, after 6 speaking with an agent, they thought that it would make a 7 difficult case because Mr. Minton was now on the stand 8 lying, telling lies. If he changed his mind -- 9 MR. WEINBERG: Objection. Hearsay, your Honor. 10 THE COURT: Sustained. 11 BY MR. DANDAR: 12 Q Did you ever meet personally with law enforcement? 13 A Yes, I did. 14 Q All right. Who did you meet with? 15 A I met with FDLE Agent Lee Strope. 16 Q Did you talk about Mr. Minton and Ms. Brooks? 17 A I pretty much gave Mr. Strope a complete rundown 18 of the meetings, with the dates similar to how I laid it out 19 there in the affidavit. And after -- 20 THE COURT: Mr. Strope is with what agency? 21 THE WITNESS: FDLE. 22 THE COURT: FDLE? 23 A And after speaking with him, he asked me to give 24 Bob Minton a message. And the message was that if it is 25 determined that you have perjured yourself on the stand, Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 590 1 that he would see to it that charges would be brought. 2 BY MR. DANDAR: 3 Q This is Mr. Strope telling you to talk to 4 Mr. Minton? 5 A This is a message Mr. Strope asked me to give 6 Mr. Minton specifically. 7 Q Did you give him that message? 8 A Mmm, I wrote -- I hand-wrote what he said. I gave 9 it to my fiancee and she read it to Mr. Minton over the 10 phone. 11 Q Okay. 12 THE COURT: Mr. Prince, is it your testimony 13 here today under oath an agent of the Florida 14 Department of Law Enforcement asked you to deliver a 15 message to someone? 16 THE WITNESS: Yes, your Honor. 17 BY MR. DANDAR: 18 Q Any other meetings with law enforcement? 19 A Not about this specific incident. 20 Q Okay. Now, what was your impression, after 21 meeting with Ms. Brooks and Mr. Minton, on the meetings you 22 have just mentioned, all of these meetings -- 23 MR. WEINBERG: Objection to the form. What was 24 his impression? 25 THE COURT: Yes. What does that mean? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 591 1 MR. DANDAR: I didn't finish my sentence. 2 THE COURT: Go ahead. 3 BY MR. DANDAR: 4 Q What was your impression as to who was the person 5 who was creating the scenario that I told Mr. Minton to lie? 6 A Mr. Rinder. 7 Q And what is the basis of that? What is the basis 8 of your impression it is Mr. Rinder? 9 A Because that is what they said. 10 Q Who said? 11 A Bob and Stacy. 12 Q All right. 13 MR. WEINBERG: Well, could we just -- I mean, 14 is that -- your Honor, so his testimony is that at 15 some point Bob Minton and Stacy Brooks said that 16 Mike Rinder said for Mr. Minton to lie? 17 THE COURT: Yes. That is his testimony. 18 MR. WEINBERG: Could we date that testimony, 19 please? 20 THE COURT: Mr. Prince, is that your testimony? 21 THE WITNESS: Yes, it is. 22 THE COURT: If you could look at your affidavit 23 and tell us which one of these conversations that 24 that conversation took place. 25 THE WITNESS: Okay. Let me see if I see it Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 592 1 here. I don't seem to have my affidavit up here. 2 THE COURT: You don't? I think I have it right 3 here, if it will help. 4 MR. DANDAR: Well, I have the affidavit right 5 here. I'm sorry. I was looking at it instead of 6 listening to the Court. 7 THE WITNESS: This would have had to have 8 happened sometime after the date that I mentioned on 9 Page 5, Line 16, Paragraph Number 11 of the 3rd of 10 April or 2nd of April, sometime after that time 11 period. 12 BY MR. DANDAR: 13 Q After this -- after the 2nd or 3rd of April? 14 A Correct. 15 Q All right. Did Mr. Minton or Ms. Brooks tell you 16 this on more than one occasion? 17 A Well, the subject of the meetings -- after they 18 returned to Clearwater with Mr. Bunker April 2nd, the many 19 times that I met with them, the subject of the conversations 20 concerned what they were asked -- or what they were being 21 asked to do, what they wanted me to do. 22 So that was a continuing theme until, you know, 23 the point that it finally broke off, because I didn't, I 24 guess, qualify to meet with the Scientologists or speak with 25 them about this myself. But it was a continuing theme of Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 593 1 conversations. 2 THE COURT: I believe that, in fairness, 3 Mr.~Prince may have testified to some of this 4 yesterday, too. 5 MR. DANDAR: I think so maybe. 6 THE COURT: And may have dated some of this 7 yesterday. I'm looking through his affidavit. I am 8 remembering some of his testimony from yesterday. 9 MR. DANDAR: All right. 10 BY MR. DANDAR: 11 Q Now, Mr.~Prince, yesterday you talked about Volume 12 0 and 00. Do you recall that? You looked in the book 13 Introduction To Ethics and you said -- 14 A Yes. 15 Q -- what you were looking for may be in Volume 0 16 and 00? 17 A Yes. 18 Q And there are a bunch of books over there. Are 19 there any of the books you want to refer the Court to? 20 A Sure, if I could just walk over there. 21 MR. DANDAR: Is that all right, Judge? 22 THE COURT: Yes. By the way, Ms. Greenway 23 asked if she could take my picture. You can't take 24 pictures when court is in session. So I gave her 25 permission to come in and take pictures when court Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 594 1 wasn't in session of whatever she wanted to take 2 pictures for. But when court is in session you 3 cannot take pictures unless you are connected with 4 the media and you are a pool photographer. Then you 5 can. 6 BY MR. DANDAR: 7 Q No other books? 8 A No. 9 Q All right. 10 A This is -- first off, I would like to say 11 yesterday that I said that this was a crime for a person to 12 give testimony about Scientology. I actually misspoke. It 13 is a suppressive act to do that, according to this document 14 here, suppressive acts, suppression of Scientology, 15 Scientologists, the fair game law. 16 And what it states specifically is -- 17 THE COURT: Tell us, first of all, what are you 18 reading from. 19 THE WITNESS: Oh, sorry. 20 BY MR. DANDAR: 21 Q The book? 22 A I'm reading from HCO Division 1 Policy Volume, 23 Scientology Policy Volume. 24 THE COURT: Okay. Those are Scientology 25 policies in a book? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 595 1 THE WITNESS: Yes, your Honor. 2 THE COURT: Is there a page number? 3 THE WITNESS: Yes, your Honor. It is 553, what 4 I'm going to make reference to. 5 MR. LIEBERMAN: Could we have the date on that 6 book? 7 BY MR. DANDAR: 8 Q Copyright on the front? 9 THE COURT: Would it matter with these 10 policies -- 11 MR. LIEBERMAN: Well, some, it may. 12 THE WITNESS: This is copyright 1970 through -- 13 what is it, 1950, it looks like. These are all of 14 the copyright notices here. 15 THE COURT: Okay. I'm going to let you-all 16 take a look at it. 17 MR. WEINBERG: Now? Or -- 18 THE COURT: No. Let him go ahead and have his 19 testimony, and then before cross-examination you-all 20 can look at the book. 21 BY MR. DANDAR: 22 Q So a suppressive act is someone saying they want 23 to leave Scientology? 24 A Yes. And testifying as a hostile witness against 25 Scientology in public is a suppressive act. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 596 1 Q All right. That has to do with testifying? 2 A Correct. 3 Q What about leaving Scientology or saying you want 4 to leave? 5 A Mmm, yesterday I showed the reference and we went 6 through that. It's a high crime to publicly depart 7 Scientology. 8 Q This may be something I already marked. Let me 9 show you what has been marked as Plaintiff's Exhibit 133. 10 CS Series 22. 11 Can you identify that Exhibit 133? 12 A Yes. This is an HCO bulletin of 28 November, 13 1970, Mmm, subtitled "CS Series 22." The "CS Series" means 14 case supervisor series. It's -- it's a series that is a 15 staple or basic for persons that are supervising auditing in 16 Scientology. And this document refers to the subject of 17 psychosis. 18 Q And this document came from the PTS/SP course book 19 you read yesterday. Is that correct? 20 A Correct. 21 Q Okay. Now -- 22 THE COURT: Who is permitted to take that 23 course? Maybe you asked it before, but, I mean, if 24 I'm a new Scientologist, new public member, can I go 25 register for that course? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 597 1 THE WITNESS: You certainly could. Any 2 Scientologist in good standing -- 3 THE COURT: Could take that course? 4 THE WITNESS: Yes, your Honor. 5 THE COURT: Okay. 6 BY MR. DANDAR: 7 Q This course book also contains the search and 8 discovery bulletin? 9 A I believe it does. 10 Q Okay. Now, this particular document, Exhibit 133, 11 CS Series 22, does this have anything to do with people 12 wanting to leave? 13 A Well, if you turn to the second page, it talks 14 about the easiest ways for a case supervisor to detect the 15 insane, and we go down here to Number 6, it says: "They 16 often seek transfers or wish to leave." 17 Q Now, does this apply to staff as well as public 18 members? 19 A Absolutely. 20 THE COURT: I think this is already in 21 evidence, isn't it? 22 MR. DANDAR: I'm not sure. You told me to mark 23 this yesterday as an exhibit. 24 THE COURT: Well, now that I'm looking at it, 25 I'm thinking I read it before. But if you are not Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 598 1 sure, you want to introduce it again, why, that is 2 all right. 3 MR. DANDAR: I'm really not sure. 4 THE COURT: All right. 5 MR. DANDAR: I know we talked about this 6 yesterday. 7 THE COURT: I'm not positive if this was the 8 document, but I have read some of this before. 9 MR. DANDAR: Yes. It is quite possible. 10 MR. WEINBERG: We have no problem, but the 11 next-to-last sentence says: "The insane can be 12 helped, they are not hopeless." We don't have a 13 problem with this. But the introspection rundown 14 comes after this policy. 15 THE COURT: But you have no objection to this 16 being introduced? 17 MR. WEINBERG: No. 18 MR. DANDAR: We move it into evidence. 19 MR. WEINBERG: It was referred to in the 20 introspection rundown which was introduced three or 21 four years later, this policy. 22 THE COURT: All right. 23 BY MR. DANDAR: 24 Q Speaking of the introspection rundown, Mr.~Prince, 25 speaking of your experience, expertise, is there any part of Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 599 1 the introspection rundown that is considered religious? 2 MR. WEINBERG: Objection to his competence to 3 this because Mr.~Prince previously testified he 4 wasn't trained on the introspection rundown and 5 never -- as an auditor never did any introspection 6 rundown. 7 THE COURT: I thought he did. 8 THE WITNESS: That is correct. I did. I never 9 was -- I never stated that I was not trained on the 10 introspection rundown. 11 THE COURT: I'm sorry, what? 12 THE WITNESS: I never stated I was not trained 13 on the introspection rundown. That is false. I am 14 very trained on the introspection rundown. 15 MR. WEINBERG: What he said was he participated 16 in an isolation watch, not as the auditor, you know, 17 but as one of the people staying with Teresita. 18 THE COURT: Is isolation watch and 19 introspection rundown the same? 20 MR. WEINBERG: It is part, Step whatever it is, 21 0, 00. 22 THE COURT: All right. 23 MR. DANDAR: This will kind of answer the 24 question, I think. 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 600 1 BY MR. DANDAR: 2 Q So, Mr.~Prince, is there parts or all of the 3 introspection rundown that is religious? A religious 4 practice? 5 A Mmm, in the very first bulletin about the 6 introspection rundown, L. Ron Hubbard describes it as a new 7 technical breakthrough that marveled something else of the 8 20th century, I forget specifically what it says there. But 9 it was hailed as a researched scientific discovery for 10 handling insanity. 11 MR. WEINBERG: So, your Honor, is what 12 Mr. Dandar is doing is challenging whether or not 13 the introspection rundown is part of the religion of 14 Scientology? Because if he is, I think that has 15 already been decided in this case and it is not 16 appropriate and we should not be wasting our time on 17 it. 18 THE COURT: Haven't we decided that -- or -- I 19 don't know because I don't know -- I saw a motion 20 once that dealt with religiocity. I didn't hear any 21 of that. 22 MR. DANDAR: That was not the -- 23 MR. LIEBERMAN: But you have stated several 24 times, your Honor, that there is no question in this 25 case as to the religious nature of Scientology or Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 601 1 religious nature of the introspection rundown. 2 THE COURT: Okay. I know I have stated that I 3 have no question on the -- that the Church of 4 Scientology is a religion and it is a recognized 5 religion in the Church. And I have no question in 6 my mind that Lisa McPherson was undergoing some sort 7 of introspection rundown. I didn't know whether I 8 said that introspection rundown is part of the 9 religion of the Church. I don't even know if that 10 is a call for me to make, to tell you the truth. I 11 would suspect the Church doctrine would tell us 12 whether it is or isn't. 13 MR. LIEBERMAN: That is correct. And the 14 Church characterizes what is religious practice. 15 THE COURT: I don't know if I have seen that or 16 not. I know we have a Mr. Rice affidavit. I 17 haven't looked at it in some time. 18 MR. LIEBERMAN: And he quite clearly places it 19 within the Scientology practice. In fact, every 20 part of Scientology, by definition, is part of 21 Scientology belief and practice and is not a matter 22 for the Court to challenge what is characterized by 23 the Church as this religion. 24 THE COURT: I am going to let him answer this. 25 I think he already has answered it, but I don't know Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 602 1 we're going to go there. And certainly one answer 2 isn't going to get it there. 3 MR. DANDAR: Right. 4 BY MR. DANDAR: 5 Q Mr.~Prince, Mr. Hubbard called it scientific 6 breakthrough? 7 A That is correct. 8 Q Did he ever call it religious practice? 9 A Never. 10 Q Did he call auditing a religious practice? 11 A No. 12 Q Oh. 13 A Not to my knowledge. I mean, this whole business 14 of religion -- I don't know, you know, it is kind of -- has 15 kind of reared its head in Scientology every now and again. 16 When I was here at the Flag Service Organization 17 in 1979, there was a scare -- a cold war scare of some 18 nuclear threat and conscription in the Army and on and on. 19 This is what we were told. So all of the staff had to do a 20 two-week course called the minister's course where you are 21 instantly trained to be a minister. This was part of -- a 22 program which, in part, was to kind of improve or create a 23 religious image for Scientology. 24 But if you will notice, in every document that 25 Mr. Hubbard writes about Scientology, whether or not it is a Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 603 1 green -- 2 THE COURT: I don't want to hear this. The 3 United States Government, State of Florida, on and 4 on down, determined Scientology is a religion, the 5 Church of Scientology is a church. I don't care 6 what they used to think, what they used to say. It 7 doesn't matter. That is it. 8 MR. DANDAR: What I'm -- I was getting at is 9 just the introspection rundown itself. 10 THE COURT: Okay. 11 BY MR. DANDAR: 12 Q The part of the introspection rundown talking 13 about get some rest -- 14 MR. WEINBERG: Your Honor, could I -- 15 BY MR. DANDAR: 16 Q -- make sure you eat -- 17 MR. WEINBERG: This is precisely why Mr.~Prince 18 should not be an expert, considered an expert in 19 Scientology, because as he sits here today, he still 20 is sitting there saying it is not even a religion or 21 a church. He doesn't recognize it -- 22 THE COURT: He wasn't. He was talking about 23 some things that were said back in the 1970s when 24 they were all sitting around talking -- 25 MR. WEINBERG: He just said that -- well, I Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 604 1 don't want to argue with you. I mean, it -- that is 2 where he was going with this and that is what 3 this -- that is what this is about. 4 MR. DANDAR: It is not what this is about. I 5 just asked him what I'm asking him now, the 6 introspection rundown, the part that talks about 7 resting and eating -- resting and eating, something 8 else -- 9 THE COURT: 0, 00. 10 MR. DANDAR: Yes, those two steps. 11 BY MR. DANDAR: 12 Q In your experience within the Church of 13 Scientology, was that ever considered a spiritual or 14 religious part of Scientology? 15 MR. LIEBERMAN: Your Honor, again, this is 16 unconstitutional inquiry. You can't bifurcate a 17 religious practice and say part is and part isn't. 18 To just even hear this testimony is an 19 unconstitutional attack on the religion. 20 THE COURT: Mr. Lieberman, your objection on 21 that is preserved. 22 MR. LIEBERMAN: Thank you. 23 A Well, you know, since -- you know, people that are 24 atheists or other ideas also rest and sleep. You know, it 25 never came to me that this was a religious experience to Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 605 1 rest and eat. 2 BY MR. DANDAR: 3 Q Well, and in your knowledge of Scientology, if 4 someone is injected with Valium or chloral hydrate, are they 5 eligible to have auditing? 6 A According to -- Mmm -- the HCO bulletin entitled 7 Model Session -- 8 Q How do you spell that? 9 A Model, M-O-D-E-L, model session, a person who has 10 had drugs or who has used drugs continuously is not eligible 11 for auditing until six weeks after the period of taking the 12 drugs. 13 Q Now, in your experience with Teresita, you said 14 Dr. Dink, Hubbard's doctor, came out and injected her with 15 some kind of drug? 16 A Correct. 17 Q And she went to sleep? 18 A Correct. 19 Q How soon after that did she have auditing? 20 A Within hours after awaking. 21 Q Was that within the written policy? 22 A Is that what now? I'm sorry. 23 Q Is that per policy to have an auditing right after 24 you have slept off the effects of the drug? 25 A Well, in the introspection rundown bulletin, it Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 606 1 states that each program is tailored specifically for the 2 individual. So to that degree, if the person had to sleep 3 first in order to get auditing, they would get the auditing, 4 but then there is also later references in Scientology 5 technology which state that in a period after the auditing 6 that was delivered, while the person was on drugs, you could 7 then go back and check those areas again to make sure that 8 everything is fine. 9 Q Okay. Let me show you Exhibit 134. And do you 10 recognize where this copy of this Page 258 comes from? 11 A Yes. This comes from the Hubbard Administrative 12 Dictionary. 13 Q And what -- how does it define the phrase "high 14 crimes"? 15 A It says: "High crimes. 1. These consist of 16 publicly departing Scientology or committing suppressive 17 acts. Cancellation of certificates, classifications and 18 awards and becoming fair game are amongst the penalties 19 which can be leveled for this type of offense as well as 20 those recommended by Committees of Evidence." 21 MR. DANDAR: Okay. That is all of the 22 questions I have. 23 THE COURT: All right. Thank you. You may 24 inquire. 25 MR. WEINBERG: Thank you. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 607 1 CROSS-EXAMINATION 2 BY MR. WEINBERG: 3 Q Mr.~Prince, David Miscavige busted you from your 4 position of authority -- your executive position of 5 authority in the RTC -- in March of 1987, didn't he? 6 A Correct. 7 THE COURT: I'm sorry, you just got started. 8 Did you want to introduce this 134? 9 MR. DANDAR: Yes, sir. In fact -- 10 MR. WEINBERG: We object to that. I would like 11 to see the dictionary, see what the date of the 12 dictionary was. 13 MR. DANDAR: Do you have it here? In fact, I 14 just realized, unless you want to do this later, 15 there are a bunch of things I marked and didn't move 16 them into evidence. 17 THE COURT: I'll go ahead and let you do 18 that -- 19 MR. DANDAR: Later? 20 THE COURT: -- later. But don't forget. 21 MR. DANDAR: Right. Yes. 22 MR. WEINBERG: Should I start over? 23 THE COURT: Yes. 24 BY MR. WEINBERG: 25 Q Mr.~Prince, David Miscavige busted you from your Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 608 1 position -- your executive position of authority in the RTC 2 in March of 1987, didn't he? 3 A Correct. 4 Q And at that time you were removed from your post, 5 the last executive post you ever held in the Church of 6 Scientology. Correct? 7 A Correct. 8 Q And that post, you said, was deputy inspector 9 general external. Right? 10 A Right. 11 Q Now, you were removed because you had supported 12 Pat Broeker and Annie Broeker and Vicki Aznaran in their 13 effort to change Scientology tech. Correct? 14 A That is categorically false. 15 Q That was precisely what occurred, that Pat 16 Broeker, who had designated himself the loyal officer, was 17 in the process of changing, among other things, the 18 Scientology grade chart, right? That is what he was doing? 19 A That is categorically false. 20 Q So Mr. Broeker wasn't doing that? 21 A Correct. 22 Q And you never acknowledged that Mr. Broeker did 23 that? 24 A Correct. 25 Q So Mr. Broeker wasn't off on his own, trying to Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 609 1 change the religion of Scientology, after Mr. Hubbard died? 2 A Well -- 3 Q Yes? Or no? 4 A Excuse me. Let me answer the question. 5 THE COURT: Well, I'll tell you how this works 6 on cross-examination. Go ahead and answer the 7 question, but if you feel you have to explain your 8 answer, you are allowed to do that after you have 9 answered it. 10 THE WITNESS: Okay. I'm sorry. 11 A Ask me the question again. 12 BY MR. DANDAR: 13 Q Wasn't Mr. Broeker caught in -- in an attempt to 14 change Scientology tech? 15 A I have no percipient knowledge of that. 16 Q You have no percipient knowledge of that? 17 A In other words, I was not there -- let me -- I was 18 not there. I didn't see him changing anything. 19 And, again, I was going to say, I have heard some 20 hearsay about it. Since you vehemently object about it, I 21 won't comment about it, but I -- you know, I haven't 22 personally been with Mr. Broeker when he's altering 23 Scientology technology. 24 Q When you were in the RTC prior to March of 1987, 25 in that year after Mr. Hubbard died, you became aware of the Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 610 1 fact that some point in time that Mr. Broeker was changing 2 and altering Scientology tech, weren't you? 3 A Incorrect. 4 Q You became aware of the fact that Vicki Aznaran 5 was part of an effort to change Scientology tech, weren't 6 you? 7 A Absolutely incorrect. 8 Q And what happened in March of 1987 is that 9 Mr.~Broeker was removed from all authority. Correct? 10 A Mr.~Broeker was removed from authority. 11 THE COURT: Wasn't? Or was? 12 THE WITNESS: He was, your Honor. 13 BY MR. WEINBERG: 14 Q Annie Broeker, his wife, was removed from all 15 positions of authority. Correct? 16 A To my knowledge, that is correct. 17 Q Your boss, Vicki Aznaran, was removed from her 18 position of authority. Correct? 19 A Correct. 20 Q And you were removed? 21 A Correct. 22 Q And you were at that time -- at that point in 23 time, you went from what you described as an executive 24 position with some authority in the -- in RTC. Right? 25 A Correct. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 611 1 Q To no authority whatsoever? 2 A No. That is incorrect. 3 Q From -- for the next five years after March of 4 1987, did you ever hold a position where someone was junior 5 to you? You know what I mean by that? 6 A Yes, I do. And, yes, I have. 7 Q I mean, you were, what, a machine operator after 8 that? 9 A Mmm, no. I worked on post-production, 10 preproduction and post-production for films. 11 Q That was one of the things you did, and you were a 12 Cinemix, was that your job? 13 A No. 14 Q What was your job? 15 A My job was like an assistant engineer, assistant 16 sound mixer. Again, I state I worked for post-production 17 and preproduction for films and videos. 18 Q During that period of time you were in the RPF a 19 couple of times. Correct? 20 A Incorrect. 21 Q How many times were you in the RPF? 22 A I was in the RPF two times, but not that period of 23 time. 24 Q You were in the RPF in March of 1987. Correct? 25 A Correct. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 612 1 Q All right. Until what, the end of 1987? 2 A Mmm, I think it was -- I wasn't in there a very 3 long time. I think maybe four months. 4 Q By the way, there is no higher crime in 5 Scientology than changing the tech. Correct? 6 A That is incorrect. 7 Q Well, what would be a higher crime than changing 8 Mr. Hubbard's scriptures? 9 A Placing Scientology and Scientologists at risk. 10 Q One of the highest crimes in Scientology is to 11 alter the tech. Correct? 12 A It is a high crime to do that. Yes. 13 Q Now, for the next -- for those five years after 14 you were busted -- and that was the day you claimed, by the 15 way, that you pulled these guns on David Miscavige and 16 threatened to kill him? 17 A You didn't mention a specific day. What day are 18 you talking about? 19 Q Well, what day are you talking about when you were 20 busted? 21 THE COURT: Without worrying too much about the 22 date, the date you testified about when you were 23 rousted from bed or got out of bed and went and got 24 the guns, that is on the same day, right? 25 THE WITNESS: Yes. I'm sorry. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 613 1 THE COURT: That is the day you were busted? 2 THE WITNESS: Yes. 3 THE COURT: That is what he was referring to. 4 THE WITNESS: Okay. I'm sorry. I just didn't 5 understand the question. 6 BY MR. WEINBERG: 7 Q That is the same day you claim you pulled these 8 guns on David Miscavige and you threatened to kill him. 9 Correct? 10 A I didn't threaten to kill Mr. Miscavige. What -- 11 maybe you have a wrong idea about what happened there. I 12 came there to defend myself. Twelve people were attacking 13 me, were trying to hold me. Because I do know karate and 14 have a black belt in it, I was able to get them away from me 15 until I went and got protection for myself. 16 Q So then these twelve people that were attacking 17 you let you go back to your room, get these two loaded guns? 18 A They didn't know where I was going. 19 Q That didn't really happen, did it, Mr.~Prince? 20 A Yes, it did. 21 Q You didn't pull guns on David Miscavige. 22 A Yes, it did. 23 Q So this is the person you say you could still be 24 friendly with? 25 A You know, Mmm -- yes. And I need to explain Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 614 1 something here because, you know, Mr. Weinberg, you and I 2 have been around and around on this in front of Judge Moody. 3 So, you know, you are giving me the exact same questions and 4 I'll sit here and be patient with you, but I think the 5 record reflects we have done this one or two times before. 6 THE COURT: See, I haven't heard it. This is 7 my hearing, so we'll do it again. 8 MR. DANDAR: Explain yourself. 9 THE WITNESS: Okay. 10 BY MR. WEINBERG: 11 Q So you contend that you really did go back to your 12 room, get two loaded weapons, and walk back and enter a room 13 and point them directly at David Miscavige? 14 A No, I never walked back into a room. By that 15 time -- 16 Q You ran back into the room? 17 A Would you like me to explain it? I -- 18 Q Explain it. 19 MR. DANDAR: Wait. Wait. Objection. 20 BY MR. WEINBERG: 21 Q Did you -- 22 MR. DANDAR: He needs to explain it. 23 Mr. Weinberg -- 24 MR. WEINBERG: I'll withdraw that question. 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 615 1 BY MR. WEINBERG: 2 Q Did you point two loaded guns -- 3 MR. DANDAR: That is not fair. 4 BY MR. WEINBERG: 5 Q -- at David Miscavige? 6 A No, I did not. 7 Q Who did you point them at? 8 A I had the one gun on my hip and the .45 in my 9 hand. And they stood this way. The assault rifle never was 10 pointed at anyone. It was just on my hip like this. And I 11 had the .45. 12 And Mr. Miscavige, when he saw me, walked directly 13 up to me with those guns in my hand and said, "Jesse, we are 14 friends. Let's talk." 15 So I don't think he felt that threatened. And I 16 think that Judge Moody pointed that out to you the last time 17 we were doing this. 18 Q I mean, no one would feel threatened when they had 19 just busted somebody from position and the person got so mad 20 to go back to the room and get two loaded guns and walk into 21 a room. You can't imagine anybody would be threatened by 22 that, would they? 23 A I think that is a mischaracterization of what 24 happened. 25 Q Well, my question is was there a particular reason Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 616 1 why you never told that story until -- until you started 2 getting paid to be a witness in the FACTNet case in 19 -- 3 whatever it is, 1998? Why you waited all those years to 4 tell that story? 5 A Mmm, I don't know how to answer that question, 6 Mr. Weinberg. You are associating things that don't 7 associate. You are associating with me being paid telling 8 stories. And there is no association there. 9 Q Well, is there a particular reason, in the years 10 after this alleged incident took place, that took you until 11 1998 to first tell this story about pulling guns on David 12 Miscavige? 13 MR. DANDAR: Object to the form. It makes no 14 sense. Telling stories where? Under oath? In a 15 deposition? To his friends? 16 THE COURT: I don't, either, because I don't 17 know whether you are talking about the first time he 18 ever testified about that, and if that is the first 19 case he was ever involved in, that is the first time 20 he ever testified about that. 21 MR. WEINBERG: I -- 22 THE COURT: I'll tell you one thing -- 23 MR. WEINBERG: I'm sorry, I didn't mean to -- 24 THE COURT: -- don't get ahead of me because 25 you want to go at this witness. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 617 1 MR. WEINBERG: You are right. 2 THE COURT: I won't have it. 3 MR. WEINBERG: Right. 4 THE COURT: I won't have you really cutting 5 this man off. I mean, I know you want to get where 6 you want to go. But you'll have to go slow. 7 And, Mr. Prince, whatever you told Judge Moody, 8 I haven't heard it, I haven't seen too much of the 9 transcript before Judge Moody, so I don't want to 10 hear what I -- I already told Judge Moody this, I am 11 not Judge Moody. 12 THE WITNESS: I understand. 13 THE COURT: If he asks you a question, unless I 14 tell him, "You can't ask that question," just 15 answer, even if you have already answered it before. 16 Okay? 17 THE WITNESS: Okay. Yes, your Honor. 18 THE COURT: Let's go. 19 BY MR. WEINBERG: 20 Q You were interviewed by Earle Cooley while still 21 in the Church in 1988, weren't you, in relation to another 22 lawsuit? 23 A I would have to see something about that. I'm not 24 sure what you are talking about. 25 Q You didn't say anything about the guns to him, did Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 618 1 you? 2 A Again, I would have to see what you're talking 3 about. 4 Q Well, you mention the 1994 interview with 5 Mr.~Cooley. You didn't say anything about the guns to him 6 in that interview, did you? 7 A I mean, you know, you are mixing apples and 8 oranges. I mean, I don't understand what you are asking me. 9 I mean, I have told that story long before 1998 to my 10 friends, my family, people that I know. I mean, you know, 11 it isn't like here is some money, let's tell this story. I 12 beg to differ with the way you are characterizing what 13 happened here. 14 Q The reason you told the story to Mr. Minton in 15 April of this year was to threaten him as to what you would 16 do as to what kind of person you were? I mean, what did you 17 tell him about it for? 18 A I told him that story, as I gave testimony 19 yesterday, to show that Scientology, more than likely, will 20 never keep or honor an agreement with anyone. It wasn't to 21 say I'm going to run and shoot you with guns. It was to 22 give him an example to show him that Scientology will never 23 honor an agreement. 24 Q Now, you would agree that the positions that you 25 held after you were busted were extremely low positions in Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 619 1 the Church of Scientology? 2 A I would beg to differ on that, as well. 3 Q Now, you were -- you were so humiliated, 4 apparently, by Mr. -- what you claim Mr. Miscavige did in 5 March of 1987 that you pulled these guns on him. That is 6 what it was about, wasn't it? 7 A Absolutely not. And even as we have been sitting 8 here, I think I made it clear to you why I went and got 9 those guns. It wasn't humiliation. It was being attacked. 10 Q You were -- 11 A Physically attacked. 12 Q You resented the fact that you had been busted? 13 A I resented the fact I was being physically 14 attacked by people that used to be my friends. 15 Q No. My question is did you resent the fact that 16 you had been busted from your executive position in RTC? 17 A And I'll answer the question it isn't so much that 18 I resented the fact that -- 19 THE COURT: Come on, Mr.~Prince, of course you 20 must have been annoyed. I don't know why we're 21 playing a semantics game. Anybody would be annoyed 22 if they were busted from the position they 23 thought -- 24 THE WITNESS: No, your Honor, that isn't right. 25 I think that deserves clarification because I was Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 620 1 pretty much tired of that activity that I had been 2 involved in, in Scientology. I was ready for a 3 change. I was ready to be done with that position 4 because that -- that position responsibility 5 entailed being involved in criminal activity. 6 This is something that I had not experienced in 7 Scientology prior to going to Gilman, Hot Springs 8 and working at that level. To me, Scientology was 9 something different than what I was doing. 10 So, no, it wasn't a big deal for me, you know. 11 I was already wanting to be away from that 12 responsibility. 13 But what was a big problem for me was twelve 14 people grabbing me, because I had an earlier 15 incident of that happening in Scientology where six 16 people grabbed me and locked me in a room for three 17 months, and I ended up staying 16 years. So that 18 had precedent over that position I was being removed 19 from. 20 BY MR. WEINBERG: 21 Q So you were relieved by the fact you were busted 22 from your position? 23 A Yes. I was somewhat relieved by it. 24 Q Now, you -- you, Jesse Prince, dislike vehemently 25 David Miscavige, don't you? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 621 1 A I would not say that that is true. I have no 2 vehement dislike for him. I dislike the things that he 3 does. But I don't envy his position. He's the leader of a 4 religion. He has a lot of responsibility. That doesn't 5 give you license to be a criminal, though. 6 Q You spent the last four years, ever since you met 7 apparently sometime in the summer of 1998, started getting 8 paid by, ever since you met Mr. Minton, you spent the last 9 four years trying to destroy David Miscavige, haven't you? 10 A That is incorrect. 11 Q You have picketed where you have spoken vilely and 12 obscenely about Mr. Miscavige, haven't you? 13 A Yes, I have. 14 Q You have picketed various Churches of Scientology 15 around the country and even in the world, correct? 16 A That is incorrect. I never picketed an 17 organization outside of the United States. 18 Q Just in this country? 19 A Correct. 20 Q You have threatened David Miscavige in these 21 pickets, haven't you? 22 A I need you to clarify what you mean by threatened 23 for me, please. 24 Q Threatened to do harm to him. 25 A I have jokingly alluded to it, yes, I have. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 622 1 Q You thought it was funny? 2 A Yes, I did. 3 Q And did you think it was funny when you were 4 outside the various Churches of Scientology, including what 5 you call the mecca of Scientology, holding signs and 6 shouting obscenities about the leader? You thought that was 7 funny, too? 8 A I -- I think you would have to show me or present 9 evidence that I was holding a sign, shouting obscenities. 10 Q Oh, we will, Mr.~Prince. 11 A Okay. I would like to see that. 12 Q Did you think that was funny? 13 A I would like to see the evidence, please, sir. 14 Q Would you consider, sir -- I mean, I think you 15 said that Mr. Minton was the -- something basically the most 16 harassed person you'd ever seen, something to that order? 17 A Something along that order, correct. 18 Q Would you consider what you and Mr. Minton and 19 Ms.~Greenway and Mr. Alexander and Mr. Oliver and the other 20 folks at the LMT -- would you consider what you were doing 21 harassing Scientology? 22 A Well, what were we doing that was supposed to be 23 harassing? 24 Q I mean -- 25 THE COURT: His question to you is whatever it Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 623 1 was you were doing, would that be, in your mind, 2 harassing Scientology? 3 THE WITNESS: Well, I guess to clarify it, if 4 it meant picketing, does that mean harassing 5 Scientology? It has a broader meaning to me. It 6 means I'm exercising my First Amendment rights as a 7 citizen to protest. 8 Mmm, if you want to call that harassing 9 Scientology, I call it exercising my freedom. 10 BY MR. WEINBERG: 11 Q I'm asking you, because remember you talked about 12 the harassment time line of Mr. Minton? 13 A Yes. 14 Q Do you remember talking about that? 15 A Yes. 16 Q And my question to you, if -- if we put all of 17 your pickets and all Mr. Minton's pickets and all your 18 postings and all Mr. Minton's postings and all of the 19 postings of these folks that have been in and out of the LMT 20 and all the pickets of them on a time line, do you think 21 that time line might be somewhat larger than this Minton 22 harassment time line? 23 A I think it would be minuscule and it would pale by 24 comparison. 25 Q By the way, are you part of an anti-Scientology Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 624 1 movement? 2 A I have never been part of an anti-Scientology 3 movement. 4 Q Are you an anti-Scientologist? 5 A No, I am not. 6 Q What do you consider yourself? 7 A I consider myself in the instant case where I'm 8 sitting right here today an expert witness concerning 9 Scientology. 10 Prior to that, I worked in an establishment 11 whereby I helped people who had been victimized by 12 Scientology. 13 Q And would you consider Mr. Minton to be an 14 anti-Scientologist during those four years that you were 15 part of the A team, I think you said? 16 A I consider Mr. Minton to be an activist. 17 Q An activist? 18 A Yes. 19 Q What is that? 20 A You tell me what it is. Do you need to know what 21 the word means? I mean, he was an -- 22 Q What do you mean -- 23 A -- activist concerning -- 24 Q What do you mean when you say he was an activist? 25 A He was an activist ensuring the rights, basic Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 625 1 human rights, that are accorded to us through our 2 constitution. 3 I think Mr. Minton got started on his relationship 4 with Scientology when he found out a Scientologist was 5 trying to remove the name "Scientology" from a newsgroup -- 6 or at least this is the way he explained it to me. And how 7 lawyers and raids and things would come to even discuss 8 Scientology, which is how I knew it from being in 9 Scientology. 10 I knew if you ever spoke about Scientology outside 11 of Scientology, you would get clobbered. So to actually see 12 people doing it openly on the Internet was -- 13 THE COURT: That is well past the answer. You 14 don't have to -- we have to try to get through this. 15 THE WITNESS: Okay. 16 THE COURT: He simply asked you to define what 17 an activist was. And I think you have done that. 18 THE WITNESS: All right. 19 BY MR. WEINBERG: 20 Q Now, when did you begin -- when did you begin your 21 work against Scientology? What date or time? 22 A Mmm, I began to give testimony concerning 23 Scientology, to the best of my recollection, in the FACTNet 24 case. 25 Q Specifically, up until I -- I think you said you Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 626 1 considered yourself a Scientologist until, I think you said, 2 1997. Correct? Isn't that what you said in your testimony? 3 A I think maybe '96, I said. 4 Q All right. So you considered yourself a 5 Scientologist after you left the Church of Scientology in 6 1992, after you say that you were -- you said all those 7 horrible things happened to you in the five-year period, you 8 still considered yourself a Scientologist in '93, '94, '95 9 and '96. Correct? 10 A I think I should clarify that for you, if that is 11 okay. I think that I still had Scientology values. I think 12 that I still respected some of the tenets of Scientology, 13 and I freely associated with Scientologists. 14 Q Well, you were working for a public member of 15 Scientology for several years, right? 16 A Several years is incorrect. 17 Q How many years? 18 A Maybe one. 19 Q This is the job that the Church had helped you get 20 after you left the Church where you were making $60,000 or 21 $70,000 a year. Was that your testimony? 22 A I think you are mischaracterizing what happened. 23 No, that is not my testimony. The Church didn't help me do 24 anything. It never has. 25 Q Well, just tell us one of those Scientology values Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 627 1 that you -- that you continue to accept and feel close to 2 after you left the Church of Scientology. 3 A That man -- man is a spiritual entity. That -- 4 Mmm -- man is capable of seemingly -- seemingly more capable 5 than is realized and those potentials can be cultivated and 6 used and expanded on. 7 Q Any other ones? 8 A You know, some of the organical principles about 9 the importance of organization, the importance of schedules. 10 You know, these kind of things. 11 Q When you were a Scientologist, you believed, did 12 you not, that psychiatric problems were spiritual in nature. 13 Correct? That is what you believed? And could be dealt 14 with spiritually through the religion of Scientology. You 15 believed that when you were a Scientologist, didn't you? 16 A Yes, I did. 17 Q And that is what Scientologists believe, don't 18 they? 19 A I can't speak for all Scientologists. I know 20 that, you know, as you are trained in Scientology, you 21 accept more and more of what you read, and it's a 22 progression, it is a degradation of belief system, I guess. 23 But I couldn't say that everyone believes that. 24 Q Well, you could say that Scientologists -- no 25 Scientologist would want to be committed to a mental Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 628 1 institution. You can say that, can't you, from your years 2 as a Scientologist? 3 A Mr. Weinberg, I can say that about Scientologists 4 and anyone else. There is no one that I know that is aching 5 to be committed to an institution. 6 Q But I'm asking you from when you were a 7 Scientologist -- 8 A Uh-huh? 9 Q -- the last thing that you would have -- you would 10 have rather shot yourself than be committed to a mental 11 institution? 12 A Absolutely not. I mean, that is unreasonable. It 13 is irrational. 14 Q Well, can you think of anything worse, as a 15 Scientologist, than to be committed to a mental institution? 16 Can you just answer that question? 17 A Rehabilitation Project Force, maybe. 18 Q One of the fundamental principles of the Church 19 is -- is the Church's abhorrence with psychiatry and mental 20 health treatment. Correct? 21 A Well, you know, Mr. Weinberg -- 22 Q Can you just answer that question? 23 A I used to believe that is the answer. I used to 24 believe that. But I found, from Mr. Hubbard's autopsy 25 report that I had a copy of, that he himself was taking Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 629 1 psychiatric medication -- 2 MR. WEINBERG: Objection. Move to strike. 3 A -- in his life. So maybe -- 4 THE COURT: Stop. There is an objection. You 5 have to stop. 6 MR. WEINBERG: It is not responsive to the 7 question. It was a very simple question. Yes or 8 no. 9 MR. DANDAR: I would say this is outside of the 10 scope of direct and the issues. 11 THE COURT: It is not outside the scope of 12 direct and not outside the scope of the issues but, 13 quite frankly, this is not helping me any. 14 MR. WEINBERG: All right. 15 THE COURT: It is an interesting banter between 16 you and Mr.~Prince and -- 17 MR. WEINBERG: I'll go on. 18 THE COURT: -- this might be of interest to a 19 jury, but it really isn't of interest -- 20 MR. WEINBERG: All right. 21 THE COURT: -- to me. 22 BY MR. WEINBERG: 23 Q Since you have met Bob Minton, all of the money 24 that you have received since June, other than this 25 apparently $4,000 that you just got from Mr. Dandar, that Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 630 1 you have received since June, July, of 1998, up until April 2 of 2002, came directly or indirectly from Mr. Minton, didn't 3 it? 4 A That is incorrect. 5 Q And all of the money -- all of the money that you 6 have received in that period of time you received as a 7 result of your work about or against or involving 8 Scientology? 9 A That is incorrect. 10 Q Correct? 11 A That is incorrect. 12 Q What is incorrect about that statement? 13 A I think that -- Mmm -- that all of the money that 14 I have had during those periods of time derived from those 15 activities, that is -- specifically is incorrect about it. 16 Q What, 99 percent of it? 95 percent of it? 17 A You know, I have turned over my financial records 18 to you. I think they speak for themselves. 19 Q All right. Let me play you -- because you asked 20 me to -- let me play you a video -- some videos and maybe 21 this will refresh your recollection. I'll ask you some 22 questions about it. 23 A All right. 24 MR. WEINBERG: Get the first one. 25 MR. DANDAR: We're going to object. If he Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 631 1 plays the video that they would like to play from 2 the Boston picket, I demand that they play the whole 3 video so that you, Judge, can see what Mr.~Prince 4 was responding to in that very vile video that you 5 may have already seen. You only saw their version 6 of it. There is like two, three, four minutes of 7 extremely vile language coming from ministers of the 8 Church of Scientology to bull bait Mr.~Prince into 9 responding the way he did on video. So if they are 10 going to do that, they need to play the whole thing. 11 MR. WEINBERG: That is not the one I'm playing, 12 first of all -- 13 THE COURT: All right. 14 MR. WEINBERG: -- to make it easy. 15 Secondly, if he wants to do something later, he 16 can. 17 THE COURT: There is a rule of completeness 18 which we'll get into when we get to trial. At a 19 trial, if somebody will try to pick and choose, I'm 20 probably going to insist on the rule of completeness 21 in an appropriate case. 22 But in this hearing, if they play something and 23 you think I need to see it all, make a little note, 24 tell them to keep it there and play the whole thing 25 on redirect. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 632 1 MR. DANDAR: All right. 2 THE COURT: Or ask them if they'll play it all. 3 If they say no, then you play it. 4 MR. DANDAR: All right. 5 MR. WEINBERG: Now, this is a video in front of 6 the Ft. Harrison on November 30, 1998. 7 ______________________________________ 8 (WHEREUPON, the video was played.) 9 "You want to see the other side of the sign, 10 too? Just want to make sure you get all of the 11 information, all of the data. 12 "Tell David I'm coming with a dick so big, I'm 13 gonna knock his goddamn spine out cuz I'm black. I 14 got a big dick. I'm black. I got a big dick. 15 "Hey. Hey. Didn't that guy have curly hair? 16 (Inaudible.) 17 "No. No. Jesse. Yo momma. I been fucking 18 your momma a long time (inaudible). That's why you 19 got that curly hair." 20 (End of playing of the video tape.) 21 ______________________________________ 22 BY MR. WEINBERG: 23 Q Do you recognize yourself, Mr.~Prince? 24 A Yes, I do. 25 Q You recognize Mr. Minton? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 633 1 A Yes, I do. 2 Q And you thought that was funny? Your statement 3 about Mr. Miscavige? 4 A Yes, I did. 5 Q You don't consider that a threat? 6 A No, I don't. 7 Q You think it is appropriate for an expert, or 8 anybody, for that matter, but particularly an expert on -- 9 supposedly on religion to be in front of the Ft. Harrison to 10 be making obscene statements about David Miscavige like that 11 to other -- to Scientologists? 12 A You know, I think there was an indiscretion that 13 happened there, certainly. 14 Q And you consider it harassment for you and 15 Mr. Prince -- and Mr. Minton and others to be holding signs 16 like the one you were holding, "Lisa, blood on her hands," 17 and the one Mr. Minton was holding about the Third Reich, do 18 you consider that harassment to be walking in front of the 19 mecca of Scientology? Do you consider that to be 20 harassment? 21 A I consider it to be exercising my constitutional 22 right -- 23 Q Okay. 24 A -- as a citizen of America. 25 MR. WEINBERG: Want to play the next one, Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 634 1 please? Actually, let me -- go ahead. 2 ______________________________________ 3 (WHEREUPON, the video was played. No audio 4 available.) 5 MR. WEINBERG: This is on the same day in front 6 of the Criminal Court Complex. 7 BY MR. WEINBERG: 8 Q Now, do you remember this being the day of the 9 arraignment in the criminal case and do you remember being 10 in front of the complex with Stacy Brooks, Bob Minton, Ken 11 Dandar, Dr. Garko and yourself? Do you remember that photo? 12 A I remember that photo. 13 Q And do you recognize that as the criminal complex 14 in Clearwater? 15 A The one on 49th Street? 16 Q Yes. 17 A Yes, I do. 18 Q And who took that photo? 19 A You know, I'm not sure. 20 Q And do you think that is funny? "Scientology, 21 Hubbard Third Reich," do you think that is funny? 22 A You know, I think those people in that picture are 23 exercising their constitutional rights. 24 Q Do you think it is appropriate for the trial team 25 of Mr. Dandar, Dr. Garko and you and Ms. Brooks, along with Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 635 1 Mr. Minton, to be standing in front of a public building 2 holding signs like that? 3 MR. DANDAR: Objection. 4 BY MR. WEINBERG: 5 Q Do you think that is appropriate? 6 MR. DANDAR: Objection. Mr. Minton is not part 7 of any trial team. 8 THE COURT: He said "and Mr. Minton." So I'm 9 assuming he was excluding him. 10 MR. WEINBERG: That is what I did. 11 BY MR. WEINBERG: 12 Q Do you consider that to be appropriate behavior? 13 A I consider that unless I'm committing a crime, I'm 14 exercising my constitutional rights as an American citizen. 15 Q Do you believe that that constitutes harassment of 16 the Church of Scientology? 17 A No, I don't. I think if I was doing anything 18 illegal, Scientology would have had me arrested on the spot. 19 Q Okay. 20 THE COURT: Harassment is not illegal. I guess 21 what he's trying to ask you is, in addition to 22 exercising your First Amendment rights, did you 23 consider that that might be considered harassment? 24 THE WITNESS: You know, and I -- my answer 25 again is no. My answer is I'm exercising my Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 636 1 constitutional rights as an American citizen. 2 BY MR. WEINBERG: 3 Q You wouldn't consider that picket -- 4 MR. WEINBERG: Can you put that photo back up? 5 BY MR. WEINBERG: 6 Q Somebody asked you -- I think Mr. Dandar asked you 7 whether or not he was ever on a picket. 8 THE COURT: Now, Counselor, in all fairness, 9 that is a picture, that is not a picket. What we 10 saw before -- 11 MR. WEINBERG: I understand. I was asking to 12 ask him. This is a picture. 13 BY MR. WEINBERG: 14 Q My question is what was going on with these signs 15 in front of the Clearwater courthouse? What were you-all 16 doing with these signs? 17 A I think we had been picketing earlier. 18 THE COURT: Was Mr. Dandar with you when you 19 were picketing? 20 THE WITNESS: Absolutely not. Neither was 21 Mr. Garko. 22 BY MR. WEINBERG: 23 Q And whose idea was it to pose for this picture? 24 A I don't know. I don't recall. I don't remember. 25 Q I mean, no one forced you-all to do this. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 637 1 Correct? 2 A Correct. 3 MR. WEINBERG: Go to the next one, please. 4 ______________________________________ 5 (WHEREUPON, the video was played.) 6 "You work for a criminal organization. And 7 they're going to be found out. You take that and 8 put it on the camera and run it to Miscavige, your 9 leader, your guru. He's going down." 10 (End of playing of video tape.) 11 ______________________________________ 12 BY MR. WEINBERG: 13 Q Now, that was right outside the Clearwater Bank 14 building where all the people go in to eat. Correct? 15 A Yes. It was. 16 Q And right down the street, as you look down the 17 street, is where the LMT offices were? 18 A That is correct. 19 Q All right. And do you consider that to be a 20 threat to Mr. Miscavige where you say he's going down? 21 A No, I do not. And I think I have to -- you know, 22 because this is just a little snippet you are showing here, 23 I think I should give the situation that was occurring. 24 On that very street that you saw me in front of 25 where the Lisa McPherson Trust is around the corner, on that Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 638 1 particular day I had gone to a shop on Cleveland to buy a 2 pack of cigarettes and go back to the office. 3 From the moment I walked out of my office, all of 4 the way up to the door of the shop I went to and all of the 5 way back, a Scientology OSA person had a camera on me like 6 this (indicating). 7 I was annoyed. If that is a crime, find me 8 guilty. 9 Q Now, was that your purpose when you say, "You're 10 going down," was your purpose to get rid of Mr. Miscavige 11 from being the chairman of the board or the ecclesiastical 12 leader of Scientology? 13 A My purpose was to express my annoyance. 14 Q And "guru," were you just being funny? 15 A Again, my purpose was to express my annoyance. 16 Q Now, was that your agenda? Strike that. 17 Was it Mr. Minton's agenda -- was part of his 18 agenda to get rid of David Miscavige? 19 A You had Mr. Minton up here -- 20 Q I'm just asking you. 21 A -- Mr. Weinberg, forever, you know. 22 Q I'm asking you. 23 A He never said that to me. He never said that to 24 me. 25 THE COURT: There is an answer in the Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 639 1 courtroom. It is called "I don't know." If it 2 is -- 3 A He never -- no, he never said that to me. 4 BY MR. WEINBERG: 5 Q Now, you described you, Ms. Brooks and Mr. Minton 6 as the A team, right? 7 A Correct. 8 Q And the A team got formed in the summer of 1998? 9 A I would say -- Mmm -- thereabouts. 10 Q Right. And the A team continued to be -- 11 A Maybe -- wait a minute. I misspoke about that 12 because that A team business didn't come up until after -- 13 after we'd worked together for a while and had done things. 14 And that concept came out -- in the summer of '98 is when I 15 first met them, so I think it would be a misrepresentation 16 to say that the A team was in the summer of '98, at least to 17 my best recollection as I sit here today. 18 Q So when was it? 19 A And I can't be sure. It was sometime later. 20 Q When you said it became the A team after you had 21 done things, what kind of things? Are you talking about 22 like -- do you mean like pickets and sending postings and 23 things like that? Are those the things that you were doing? 24 A I think more like helping people directly. 25 Q Helping people? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 640 1 A Yes. 2 Q How was Mr. Minton helping people, by standing and 3 holding signs like that? 4 A Well, you know, I guess there is a myriad of 5 answers for that. But what I meant to say, helping people, 6 I meant helping people that had run into problems with 7 Scientology and were not able to resolve them so that they 8 can get on with their lives. 9 Q Now, where did the A team concept come from? 10 A You know, I think there used to be a television 11 program. 12 Q Are you talking about the one with Mr. T? 13 A If you let me finish. You know, the reason why I 14 can't answer that question, because when those television 15 series were going on, I was in the Sea Org and we weren't 16 allowed to watch TV. So I have a big missing section in my 17 life with serial programs and things like that. 18 So again I'll say there was some program that had 19 the A team on it. And I think Mr. Minton brought it up 20 and -- but -- 21 Q And -- 22 A -- but I have never seen a program called the A 23 team or anything like that. 24 Q When you said the A team yesterday, what did you 25 mean, A team? What was it that the A team was doing? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 641 1 A The A team was myself, Bob and Stacy. And the A 2 team were helping people that needed help to resolve issues 3 with Scientology. 4 You know, just to -- to show how far at the other 5 end of the spectrums were, Mr. Minton actually thought he 6 was helping Scientology by helping these people resolve 7 issues with Scientology. 8 Q Do you remember speaking to the media about 9 bringing Mr. Miscavige down? 10 A No. I do not. 11 MR. WEINBERG: Play that next one, please. 12 ______________________________________ 13 (WHEREUPON, the video was played.) 14 "It takes standing up and recognizing it for 15 what it is, a dead, arcane idea. We're dealing with 16 people who are ignorant and we're going to bring 17 them down." 18 BY MR. WEINBERG: 19 Q Do you remember that? 20 A I object to that very -- I can't object, but that 21 was an obvious edit where you sliced two things together. 22 And I think you are mischaracterizing a speech that I gave 23 for a vigil for Lisa McPherson where the press was there. I 24 was not speaking for the press. I was speaking to former 25 Scientologists. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 642 1 Q Were you talking about bringing down Scientology? 2 Is that what you were talking about? 3 MR. DANDAR: We object and ask the whole thing 4 be played. 5 THE COURT: I think that is fair. 6 MR. WEINBERG: It was a newscast, we didn't -- 7 we can play the whole newscast. It takes a minute. 8 THE COURT: I don't want the whole newscast. 9 Just whatever Mr. Prince said. 10 MR. WEINBERG: Well, that is what Mr. Prince 11 said. That is all he said is what we just played. 12 THE COURT: Well, it did look like there was a 13 definite splice. 14 MR. WEINBERG: There was. One of these 15 newscasts where the reporter said something and 16 Stacy Brooks said something and he said the first 17 thing on there, Mr. Prince, then somebody else said 18 something, then he said the last thing. 19 We took the two things Mr. Prince said and put 20 it together. But we can play the whole section. 21 THE COURT: It makes it look like he said all 22 that together, and it may not have been. 23 I think if what it is you are trying to do is 24 every time he said we're going to bring him down, 25 what is it you mean when you say that? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 643 1 THE WITNESS: Expose -- expose what is actually 2 going on. 3 THE COURT: Okay. 4 THE WITNESS: You know, expose the fact that 5 private investigators are being used to terrorize 6 citizens because they disagree with Scientology. 7 Expose the fact that someone gave $100,000, and it 8 is Scientology's policy, if you don't use a service 9 that you paid for, they will refund it to you. 10 THE COURT: Normally, when you want to say 11 we're going to expose somebody, you don't say expose 12 somebody, you say bring them down, that kind of 13 means put them out of business. That is what I mean 14 by that. What did you mean by it? 15 THE WITNESS: I mean ending the criminal 16 activity. Ending the assault of citizens who have 17 no way to protect themselves once they get on the 18 bad side of Scientology. 19 THE COURT: When you say "We are going to bring 20 you down," this is your testimony, you did not mean 21 put the Church of Scientology out of business, do 22 away with the Church? 23 THE WITNESS: Right, in the illegal activities. 24 I never had a -- as I said, corrupt activities 25 wasn't even anything in my mind during the majority Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 644 1 of my stay in Scientology. These are things that I 2 learned about after I got to Gilman, Hot Springs, 3 and started working directly for Mr. Hubbard and 4 Mr. Miscavige. I was an ignorant, blind person to 5 it prior to that time. 6 BY MR. WEINBERG: 7 Q When you said in that newscast that I just played, 8 quote, "It takes standing up and recognizing it for what it 9 is, a dead, arcane idea," that was how you -- that -- you 10 were expressing your opinion about Scientology, that is what 11 you meant by that, isn't it? 12 A No. You have taken this out of context because I 13 don't know what "It is." You showed me a little snippet. I 14 don't know what you're talking about. 15 THE COURT: I don't, either. 16 MR. WEINBERG: I have the transcript. We'll 17 play the whole tape because we are obviously not 18 going to get done today. 19 BY MR. WEINBERG: 20 Q But -- it was a response to a question, "Today 21 they spoke out against the Church of Scientology," and then 22 they play what you said about it. But we'll play the whole 23 thing. It takes about a minute. All right. 24 You remember going on several trips to Europe with 25 Mr. Minton, correct? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 645 1 A I think I went on a couple of trips with 2 Mr. Minton. 3 Q All right. He paid for the trips? 4 A Correct. 5 Q Who else went with you? 6 A You know, as a matter of fact, I only traveled to 7 Europe with Mr. Minton one time. 8 Q And the purpose of that trip was? 9 A To visit with his business partner, Jeff Schmidt, 10 to have a face-to-face with him to find out specifically 11 what Scientology-hired private investigator David Lee was 12 doing to try to get him to a -- do a similar thing as Bob 13 and Stacy, basically turn against Bob and provide criminal 14 information so Scientology could use it to attack Bob 15 Minton. 16 Q Now, do you remember being in Germany with 17 Mr. Minton and Ms. Brooks in or about June of 2000? 18 A I think I was in Leipzig, Germany. 19 Q And Mr. Minton paid for that trip? 20 A I think that trip was paid by the Lisa McPherson 21 Trust. 22 Q So in June of 2000 you were on the payroll of the 23 Lisa McPherson Trust at that point? 24 A Correct. 25 Q You had just gone on the payroll? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 646 1 A You know, I can't remember. 2 Q And do you remember -- you remember being in the 3 DB lounge? 4 THE COURT: What is that? 5 A Yes. 6 THE COURT: What is a DB lounge? 7 MR. WEINBERG: It is a bar of some sort. 8 BY MR. WEINBERG: 9 Q Correct? 10 A We were at a train station in Leipzig, and there 11 was a bar called the DB Bar, which we thought was amusing 12 because DB means something very specific in Scientology, it 13 means degraded being. 14 Q And you were there with Ms. Caberta, we heard 15 about, the German government official that works against 16 Scientology, right? 17 A Correct. 18 MR. WEINBERG: I'll play this clip here. This 19 is something turned over to us by the Lisa McPherson 20 Trust. 21 ______________________________________ 22 (WHEREUPON, the video was played.) 23 "Okay, so -- so, Stacy, you start. DM, this 24 drink's for you. 25 "DM, this is a special toast to you coming Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 647 1 straight from the DB Lounge in Leipzig, Germany. 2 "I'm not going to call this guy DM anymore. 3 Remember what my new name for David Miscavige is, 4 the former ecclesiastical leader of the Church of 5 Scientology. 6 "I know this is going on camera. 7 "I know, but what did I say -- (inaudible). 8 "Yes -- yes, this is -- this is a toast to 9 David Miscavige, also known as Pope David I, from 10 the DB lounge in Leipzig, Germany. Up, up, up and 11 away. 12 "Now, Ursula. 13 "Hi, Mr. Miscavige. We did a great work here 14 in Germany. And we will finish Scientology soon. 15 "This is to you, Miscavige. We are so thankful 16 that you give us reason to live. Salute. 17 "Pope David I. Cheers. 18 "Cheers. 19 "Just some DBs hanging out here. 20 "David I. 21 (Inaudible.) 22 "This is to David Miscavige in the DB Lounge in 23 Leipzig, Germany at the train station. 24 "Pope David I. 25 "Cheers, Miscavige. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 648 1 "Rear Admiral. 2 (Inaudible.) 3 "Listen, listen, just -- 4 "No, just stop here now. Now listen. 5 "We all know in Grady's deposition, when Grady 6 was deposing David Miscavige, that he went ballistic 7 over the thought of Graham -- 8 "Now -- 9 "-- of Graham Berry spending time --" 10 (End of playing of the video tape.) 11 ______________________________________ 12 BY MR. WEINBERG: 13 Q Does that bring back memories, Mr. Prince? 14 A Yes. 15 Q And you think that is funny? 16 A Well, what I think you have is a home video of our 17 trip in Europe that was never made public -- Mmm -- to 18 anyone. And we were just having fun. Yes, I do think it 19 was funny. We were just having fun at the train station. 20 Q Does that man, Mr. Minton, look like the most 21 harassed person on the face of the earth? 22 A He does, to me. 23 Q And when Ms. Caberta, the German official who 24 has -- who flew over here and who is working against 25 Scientology, when she said, "We're going to finish Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 649 1 Scientology," she was talking about getting rid of it, 2 wasn't she? 3 A No. I think she was specifically talking about 4 Scientology isn't viewed as a religion in Germany. 5 Scientology is viewed as a political group. The reason 6 Scientology is viewed as a political group -- 7 THE COURT: I don't need to know that. 8 THE WITNESS: Okay. 9 THE COURT: I don't need to know, care, what is 10 going on in Germany. 11 THE WITNESS: Okay. 12 BY MR. WEINBERG: 13 Q When you talk about the reason for living, when 14 you-all were talking about, you know, David Miscavige gives 15 us a reason to -- a reason for living -- reason to live for, 16 talking about so that you can malign him, is that what 17 you-all are talking about? 18 A No. Not at all. 19 Q And do you remember -- it was cut off at the end. 20 Do you remember that -- that at that point, Mr. -- 21 Mr. Minton said something very obscene about Mr. Miscavige? 22 A I do not remember that. But, again, I'll state 23 that this was a video that we made on our trip that was a 24 private video, never made public, never put on the Internet, 25 and it is being exploited here today. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 650 1 Q Well, it sort of gives you a different impression 2 about what you-all were about, doesn't it? 3 A Who is you-all? 4 Q Excuse me? 5 A Who are you talking about, you-all? What you-all 6 were about. What are you talking about? 7 Q You, Ms. Brooks, Mr. Minton? 8 A The -- 9 Q The A team? 10 A I didn't get that impression. 11 Q Now, who took that video, this home video that 12 ended up in the LMT on this trip that was financed by the 13 LMT? 14 A I think Mr. Bunker. 15 Q So he was there, too, obviously? Was anybody else 16 on this trip? You have the A team, you have Mr. Bunker. Is 17 there anybody else on it? 18 A Not that I specifically recall. 19 Q And you-all thought the DB was kind of funny 20 because that is a Scientology term? 21 A Correct. 22 Q Now, after looking at your obscenities in front of 23 the Ft. Harrison about Mr. Miscavige, watching this toast, 24 you still think that he would be your friend? Wasn't that 25 your testimony this morning? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 651 1 A You know, I'm talking to a camera there. The 2 answer to your question is yes, I think that if he and I sat 3 down and actually had a discussion, we would certainly find 4 friendship, would be able to communicate. I mean, isn't 5 Scientology all about helping people learn -- 6 THE COURT: That didn't really answer the 7 question. You have that opinion and that is fine. 8 Then that is the answer to the question. 9 BY MR. WEINBERG: 10 Q You talk about counseling. The principal purpose 11 of the LMT, when it moved into Clearwater, was for the A 12 team and the people that were working for the A team to 13 picket and harass Scientology, wasn't it? 14 A That is incorrect beyond belief. 15 Q Okay. Now -- 16 A I would like to explain that, if I could. I would 17 like to explain why the LMT came here, since you brought it 18 up, and if you would allow me to just fully answer the 19 question. 20 Q So you were involved in the -- 21 THE COURT: I'm going to let him answer the 22 question. What was the purpose of the LMT that -- 23 what do you believe the purpose of the LMT was? 24 THE WITNESS: The purpose of the LMT -- 25 THE COURT: Fifty words or less. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 652 1 THE WITNESS: Okay, fifty words or less, and I 2 won't talk too fast for the court reporter. 3 THE COURT: That is 25. 4 THE WITNESS: When Lisa McPherson left that 5 hotel, she had no place to go. She had a minor 6 accident, stripped off her clothes, told people that 7 she needed help. She ended up back in the Ft. 8 Harrison. Seventeen days later, she was dead. 9 The reason that Lisa McPherson came to 10 Clearwater and the reason it was there, in case 11 there was another instance where someone needed a 12 safe place to go where they could come and get help. 13 That is why we were there. And that is the only 14 reason we were there. 15 And those were the dying wishes of Fannie 16 McPherson, Lisa McPherson's mother, when she was on 17 her deathbed. 18 BY MR. WEINBERG: 19 Q So all of this picketing which happened on a 20 regular basis, correct -- 21 A Incorrect. 22 Q Well, can you, like, give us an estimate of the 23 number of times you participated in a picket against the 24 Church of Scientology? 25 A Yes, I can. Let me think. Because I certainly Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 653 1 remember the first one well enough. I think I have probably 2 been involved in maybe six or seven pickets. 3 Q So in the -- 4 THE COURT: Over what periods of time, 5 Mr. Prince? 6 THE WITNESS: From 1998 to the present. 7 THE COURT: All right. 8 BY MR. WEINBERG: 9 Q So in a four-year picket -- 10 THE COURT: Four-year period. Not picket. 11 BY MR. WEINBERG: 12 Q Right, I have picket on the brain. In the 13 four-year period, you say you only picketed six times? 14 A I roughly estimated six or seven times that I 15 picketed, yes. 16 Q And do you have a sense of how many times 17 Ms. Brooks and Mr. Minton picketed in that four-year period? 18 A I do not. 19 Q A lot more than six? 20 A I believe so. 21 THE COURT: He said he didn't know. 22 MR. WEINBERG: I believe he just said "I 23 believe so." 24 BY MR. WEINBERG: 25 Q Now, in Clearwater there were other people in the Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 654 1 LMT that participated in pickets, including Peter Alexander, 2 correct? 3 A Yes. 4 Q Patricia Greenway? 5 A Yes. 6 Q Frank Oliver? 7 A I -- I can't say that I have ever seen Frank 8 Oliver carrying a sign, picketing. 9 Q So you are not aware he picketed? 10 A Correct. 11 Q Of course Minton -- of course, the A team, right? 12 A You know, I think Stacy herself maybe picketed 13 maybe five or six times, as well. But then she didn't do it 14 anymore because it was not anything she agreed with, nor did 15 she feel it was effective in handling the problem that we 16 were dealing with. 17 Q Well, let me ask you this. Do you remember that 18 on September 2, 1998 you and Mr. Minton participated in a 19 picket in Boston at the Boston Airport? 20 A At the Boston Airport? We -- I think you have 21 that in complete reverse. Scientologists picketed us at the 22 airport. 23 Q Do you have signs, "Scientology, The Third Reich"? 24 A Do I have signs? 25 Q Did you-all, you and/or Mr. Minton? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 655 1 A Mmm, it's a possibility. I don't know. 2 Q In September of '98 did you and Mr. Minton picket 3 in front of the Church of Scientology in Boston? 4 A That is possible. 5 Q Well, that is when he was actually arrested for 6 assault and battery. Right? 7 A Correct. 8 Q In October of 1998 did you picket with Mr. Minton 9 in front of the Church of Scientology in Boston? 10 A It's possible. 11 Q You remember several pickets in Boston in October 12 of '98 with one of Mr. -- one with Mr. Minton and one with 13 Ms. Brooks? 14 A I don't remember that specifically, no. 15 THE COURT: Tell me why we have to spend so 16 much times on these pickets. 17 MR. WEINBERG: Because, your Honor, it -- it -- 18 it demonstrates -- first of all, it puts the lie to 19 what we've heard all of the way through -- 20 THE COURT: But I know that this man has been 21 involved in pickets. 22 MR. WEINBERG: It is way beyond that, your 23 Honor. I mean, really -- 24 THE COURT: Pardon? 25 MR. WEINBERG: It is way beyond that. You have Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 656 1 before you a harassment time line. And Mr. Dandar 2 has spent literally 28 days suggesting that somehow 3 Mr. Minton was harassed to the point where -- where, 4 for reasons that don't make any sense to me, for 5 that purpose he would come in and incriminate 6 himself. 7 And the fact is -- we're not playing all of the 8 pickets. But when you see these clips, most of 9 which we got from the Lisa McPherson Trust in these 10 videos that were just turned over, you will see what 11 was really -- what was happening here in Clearwater. 12 THE COURT: I have no doubt that at the LMT 13 Trust they had very little use, if any, for the 14 Church of Scientology. And they picketed them 15 fairly regularly. 16 Quite frankly, if they had fallen on their 17 face, they wouldn't have cared; that they were out, 18 in essence, to undo what they perceived to be the 19 bad things that they perceived the Church of 20 Scientology did. I don't have any doubt about that. 21 I think the record is clear. So I don't know why we 22 keep going over those things. 23 There are things that are really critical to 24 this hearing. And I don't think those are it. 25 MR. WEINBERG: Well, I mean -- Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 657 1 THE COURT: It might be important to the 2 counterclaim, but not to this hearing. 3 MR. WEINBERG: Well, I mean, if you rely on, 4 for example, what Peter Alexander said, he said he 5 didn't have anything -- or essentially nothing to do 6 with it. You'll see essentially the opposite. 7 You have heard that somehow Mr. Minton was 8 harassed. And you're going to see what was really 9 going on, that the Church was harassed beyond 10 comprehension. 11 THE COURT: I have no doubt Mr. Minton harassed 12 the Church, as well as the Church harassed 13 Mr. Minton. It is just that simple. 14 MR. WEINBERG: But nothing is more -- well, can 15 I proceed with my cross-examination? 16 THE COURT: Yes. You may. 17 MR. WEINBERG: Thank you. 18 BY MR. WEINBERG: 19 Q You went on the Internet, as well, didn't you? 20 A I have been on the Internet. Yes, I have. 21 Q You made postings on the Internet? 22 A Yes, I have. 23 Q In that Leipzig toast you -- instead of using the 24 name "David Miscavige," you actually said "Miss Cabbage," 25 didn't you? That was a little joke, wasn't it? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 658 1 A Did I say that? 2 Q I'm asking you. 3 A I thought I said "Miscavige." 4 MR. DANDAR: I think we need to hear the video, 5 rather than someone's transcript. 6 MR. WEINBERG: I'm going to show you a posting. 7 THE COURT: In a posting we have heard him 8 called Rear Admiral. We know what that means. And 9 we know they called him Miss Cabbage. And they 10 don't speak kindly of David Miscavige. 11 MR. WEINBERG: I understand that. And I'm 12 going to show him, have him identify, his Internet 13 postings. 14 A I will admit -- I have said that before, Miss 15 Cabbage. I just don't know that -- if that is what you are 16 seeing there. 17 MR. WEINBERG: Could I stand up here with 18 Mr. Prince? 19 THE COURT: You may. 20 MR. WEINBERG: I have no other copies. 21 THE WITNESS: I have no idea what this is. 22 BY MR. WEINBERG: 23 Q This is your postings, isn't it? 24 A Excuse me? 25 Q This is your postings? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 659 1 A I don't think so. I think it is a fictitious 2 document created -- 3 Q So you didn't send a posting that said: "Too bad, 4 Little Miss Cabbage has a corncob up your ass, 724365. I 5 know the feeling. That is why I have him reeling, spending 6 money like a bitch kicked from a pimp. Roll on, ho, big 7 daddy can see you. Jesse." 8 A Yes, correct. But that is a fictitious document 9 that was created for the purpose of -- to malign me. 10 Q To malign you? 11 A Yes. 12 Q But you have used Miss Cabbage? 13 A Yes, I'll admit it. Freely admit it. 14 MR. DANDAR: Objection. This does not have the 15 normal E-Mail headers on it that you would find if 16 it was an original document, instead of something 17 that someone altered. 18 A I don't even know who Robert is. 19 THE COURT: I don't know. If he can't 20 authenticate that, I don't know whether -- I don't 21 know whether it is in or not. At the top it says 22 "Spread the word, bitch." Then it goes on to some 23 other comments. And that is not the way an E-Mail 24 normally -- 25 MR. WEINBERG: It is not an E-Mail. It's a Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 660 1 posting. 2 THE COURT: Well, the same thing. I don't 3 know. It would seem like this Jesse Prince, 4 Jesse77@GTE.net would be Mr. Prince's -- that would 5 be -- is that what you go by? 6 THE WITNESS: I had that in 1998, I think, when 7 I had a particular type of computer, I used to have 8 that address. But as I sit here today, I don't know 9 what name -- the name Robert. 10 BY MR. WEINBERG: 11 Q Well, when you use the word "Miss Cabbage," what 12 do you mean? 13 MR. DANDAR: Objection. That is not his 14 E-Mail. 15 THE COURT: No, he admitted that he has called 16 David Miscavige Miss Cabbage. 17 A It's an obvious derogatory use of Miscavige. 18 BY MR. WEINBERG: 19 Q And derogatory in -- I mean, in what context did 20 you use it when you used it? 21 A I don't remember. I just know that -- you know -- 22 I have said that before. I admit to it. 23 Q Now, let me show you -- see if you recognize this 24 posting. Or is this another fictitious one? 25 MR. WEINBERG: What will this be? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 661 1 THE CLERK: 219. 2 MR. DANDAR: What exhibit number is that? 3 MR. WEINBERG: 219. 4 THE COURT: The one before that was 2-what? 5 MR. WEINBERG: 218. 6 THE COURT: That did not come in because -- 7 MR. WEINBERG: He said he couldn't authenticate 8 it. 9 THE COURT: So that is not in evidence. That 10 is Number 218. This one you just gave us is 219? 11 MR. WEINBERG: Yes, your Honor. 12 THE COURT: Okay. 13 THE WITNESS: Okay. 14 BY MR. WEINBERG: 15 Q Did you make that posting? 16 A Yes, I did. 17 Q And do you consider that to be a -- a posting that 18 would indicate a derogatory view toward Mr. Miscavige and 19 the religion of Scientology? 20 A Mmm, I think that this posting is a result of the 21 Scientology operations being run on me. 22 While I'm trying to testify in a court in front of 23 a judge in Denver, Scientology hired a prostitute, had a 24 deep undercover agent, Laura Terepin, working on me, helping 25 me with the deposition, saying there are people other than Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 662 1 who they are. You know, this is an annoyance response to 2 what had been happening to me. You see I clearly speak 3 about private investigators following me. 4 In Denver, very strange things happened. 5 Q What do you mean, they hired a prostitute? 6 A A prostitute. You know, this guy from Denver -- 7 there was a private investigative agency in Denver that was 8 watching me. He brought a woman who said it was his sister, 9 who was a whore. She got a room directly across the street 10 from my -- not across the street, across the hall from my 11 room in the hotel that I was staying in. And when I came 12 out -- and she was a beautiful woman, you know. "Oh, can 13 you help me get my key," on and on and start this 14 conversation. 15 This guy says, "This is my sister. We're just in 16 town." 17 Suitable guise. Mr. Sharp will explain it to you. 18 And they started this whole routine of, "Come on. Party 19 with us tonight. We've got drugs, we have this. We've got 20 whatever." 21 I'm supposed to testify. I literally had to get 22 rid of them. 23 The other person, Laura Terepin was -- her real 24 name wasn't Laura Terepin. 25 Jolie Steckart, specifically paid by Scientology Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 663 1 to infiltrate Mr. Dan Leipold's office as I sat there 2 writing my declaration for his case. 3 It was these kind of things that annoyed me, and I 4 would write these things. 5 Q So when this hooker came to your room, you told 6 her to leave? 7 A Yes. 8 Q Or did you -- 9 A We were at the bar. And then she wanted to come 10 to the room. I'm like, "No, I have to testify." 11 Q But I think you testified previously that she 12 actually -- you let her come to your room and you did 13 something with her. Right? 14 A No. I don't think so. I don't think so. I -- I 15 think that you are fabricating that. 16 Q Now, when you say in the first sentence: "It 17 seems some people (Miscavige) just don't have the guts to 18 quit when it's over," what did you mean by that? 19 A What I meant specifically by that is that I came 20 into the case -- the FACTNet case -- Scientology had brought 21 an action against FACTNet for copyright -- certain copyright 22 violations. And -- Mmm -- I -- I remember vividly the whole 23 issue of copyrights in Scientology. I have given a -- a 24 detailed affidavit about it. 25 But the fact of the matter is the copyrights -- or Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 664 1 at least some of them -- were completely bogus. And the 2 filings of the copyrights were filed under false premises. 3 I did an affidavit against that concerning that -- 4 concerning that naming specifically the people that were 5 involved. Another officer, staff member, Pat Brice, was 6 involved, because after Mr. Miscavige dismantled the 7 Guardian's Office, there was always a section in 8 Scientology, according to its own policy, to register 9 trademarks and copyrights all of the time. 10 Q That is what you meant -- 11 A Excuse me I'm still talking. And they let that 12 lapse a period of time. So you had a large section of 13 materials that they claim copyright protection for which, in 14 fact, they did not have. And I was able to identify what 15 that was. 16 Q So that is what you meant when you said, "When 17 it's over, they just don't have the guts to know when it's 18 over"? 19 A Correct. They submit false documents to the 20 Court. I point out to the Court that the documents are 21 false and show them how, is specifically what I mean there. 22 Q The third paragraph, the last sentence, where you 23 say: "Can't you just --" talking about Miscavige now, 24 "Can't you just take it like a man? Soon you'll be in a 25 place where you'll be taking it like a man regularly," that Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 665 1 is sort of like the Miss Cabbage thing, you're talking about 2 him being in jail and sexually assaulted? 3 A I'm talking about him being incarcerated for being 4 involved in criminal activity. 5 THE COURT: Was this a posting to David 6 Miscavige, or somebody else? 7 THE WITNESS: No. It was that newsgroup, 8 alt.religion.scientology. 9 BY MR. WEINBERG: 10 Q Let me show you another one. You did hundreds of 11 these things? 12 A I don't think so. 13 Q You just felt compelled, as an expert, to go on 14 this alt.religion.scientology and say obscene things about 15 David Miscavige? 16 A At the time of these writings, I was not 17 operating -- I don't think I was -- I don't know. I don't 18 remember. I don't think I was an expert in this -- I think 19 I came in here in December of '99 when -- 20 THE COURT: I mean, there are people that learn 21 things from this case. Mr. Prince, if you are going 22 to ever testify in another case, you ought to learn 23 not to post things on an Internet, especially not to 24 be involved in vulgar demonstrations. They'll 25 always come back to haunt you in a court proceeding. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 666 1 Just like I hope Mr. Dandar learned, whether you 2 call it picket or vigil, if you are a lawyer, you 3 ought not to be there. 4 There are certain things you need to have 5 learned. I hope you learned that. 6 THE WITNESS: Your Honor, that is a true 7 statement. I have learned that from Judge Moody. 8 He taught me quite a bit about how I needed to act 9 in relationship to this. 10 And you are right, I have had some 11 indiscretions. All right, if we need to talk about 12 that, we will. 13 BY MR. WEINBERG: 14 Q I showed you what I marked as Defendant's Exhibit 15 220. Do you see that, Mr. Prince? 16 A Yes, I do. 17 Q Do you remember writing that open letter to David 18 Miscavige? 19 A Uh-huh. 20 THE COURT: That is a yes? 21 THE WITNESS: Yes. I'm sorry. Yes. 22 BY MR. WEINBERG: 23 Q And -- and this is when you are definitely 24 involved as an expert, you already worked on Wollersheim, 25 you already reviewed the PC folders for Mr. Dandar. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 667 1 Correct? 2 A Quite possibly I'll agree with you there. 3 Q And so you say in the first paragraph: "How 4 desperate you must feel. If you sit quietly and listen 5 carefully, you will hear it." 6 MR. DANDAR: Objection. I need to have the 7 question asked of the witness to identify this 8 document and make sure it is his. 9 MR. WEINBERG: He just did. 10 A This is my document. Yes. 11 MR. DANDAR: It doesn't have headers on it. 12 That is all. 13 THE COURT: Well, he has identified it, so -- 14 MR. DANDAR: All right. 15 A Yes. 16 THE COURT: You are introducing this? 17 MR. WEINBERG: Yes, I am. 18 THE COURT: It will be received. 19 MR. WEINBERG: And I -- 20 THE COURT: Honestly, I'll tell you the same 21 thing, I don't need you to read it to me. If there 22 is some part you want to point to -- 23 MR. WEINBERG: Really, the first paragraph and 24 last paragraph. 25 THE COURT: Okay. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 668 1 A Yes, I wrote -- I wrote the first paragraph, all 2 of the paragraphs in the middle, all of the way to the end. 3 And I think if you read this whole thing, you'll 4 see that I'm upset, I'm very peeved over the fact on Page 2, 5 second paragraph, that -- 6 BY MR. WEINBERG: 7 Q I didn't ask about Page 2. I asked about the 8 first paragraph. That is all I asked you. 9 A Oh, okay. 10 Q And the last paragraph. You wrote that, where you 11 quote the Bible? 12 A Correct. 13 Q And the reason for quoting this passage from 14 Revelations about "Avenge our blood on those who dwell upon 15 the earth" was what? 16 A Well, you know, if you know this passage, these 17 are the saints that died for righteousness but evil and 18 corruption carries on. And when the fifth seal is opened, 19 biblically speaking, the saints' blood will be avenged. 20 This is specifically what I'm talking about. 21 And how this relates to Miscavige and Scientology 22 is the corruption -- the agonizing activity that I had to go 23 through to deal with my children, my father, old 24 girlfriends, Scientology did their noisy investigation on 25 me. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 669 1 I wish I would have had this document when 2 Mr. Dandar was asking me do you remember noisy 3 investigations. They ran around to my entire family. I had 4 to go to Chicago, I had to go to Minneapolis, to Memphis, 5 Tennessee, to deal with friends and associates and family as 6 a result of Scientology doing their, quote/unquote, noisy 7 investigation, spreading lies and false information about 8 me. 9 THE COURT: Are you done with Number 220? We 10 need to take our break. 11 MR. WEINBERG: We offer 220. And I do also 12 offer 219, the one before that. 13 THE COURT: That will be received, too. And 14 we'll go ahead and take our afternoon break. It is 15 25 after. A 20-minute break. 16 MR. WEINBERG: Thank you. 17 (WHEREUPON, a recess was taken from 3:25 to 3:50.) 18 ______________________________________ 19 THE COURT: You may continue. 20 MR. WEINBERG: Thank you. At the break I had 21 one more of these things I was going to mark. I'll 22 go on. That is 221. 23 BY MR. WEINBERG: 24 Q Now, Mr. Prince, do you recognize Defense Exhibit 25 221 as a posting which you made on or about August 6 of Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 670 1 1998? 2 A If you'll give me just one minute -- 3 Q Sure. 4 A -- to review this document, please, I'll indicate 5 it for you. 6 Okay, yes. I do remember this document. 7 MR. WEINBERG: All right. I'll offer this, 8 your Honor. I have a couple questions to ask on it. 9 THE COURT: All right. It will be received. 10 BY MR. WEINBERG: 11 Q Now, this is one of the first postings you made 12 after you had joined the ranks of working against 13 Scientology, correct? 14 A I would hardly characterize it as that. But this 15 is one of the first postings that I made on the Internet 16 concerning Scientology. Yes. 17 Q All right. Now, in that first paragraph you say, 18 second sentence: "You know, I just can't refer to 19 Scientology as a church in any way. It would be an insult 20 to all religions." Do you see that? 21 A Yes. 22 Q And that is how you feel today, isn't it? 23 A You know, it is not. And I can explain to you 24 why. 25 Q You don't need to. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 671 1 A Okay. Then I have answered the question. 2 Q So you think it's a church? 3 A Correct. 4 Q So you just sent this out of some hatred? 5 MR. DANDAR: Objection. He didn't want him to 6 explain it. Now he's asking him. So let the man 7 explain his answer. 8 THE COURT: Well, I think that was a different 9 question. And I think that Mr. Prince is capable of 10 answering that question, then I think he can explain 11 it. 12 BY MR. WEINBERG: 13 Q You sent this out of some hatred for Scientology? 14 A Mmm, no, sir. 15 Q Now, if you go to the fourth paragraph where it 16 says, I quote: "The bottom line is that the hierarchy of 17 Scientology is composed of people who are very, very, very 18 mentally ill, sick people of the worst sort. Why? Because 19 they are sick and don't know it. In all honesty, I hope to 20 reach them so they can wake up and start getting well like I 21 have and others have." 22 You wrote that, right? 23 A Correct. 24 Q Wasn't that what you have, in essence, been doing 25 for the last four years, trying to get rid of the hierarchy Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 672 1 of Scientology, including David Miscavige? 2 A You know, that is not exactly what I say here, to 3 get rid of those people. I said I hope that I could reach 4 them so that they can wake up and start getting well 5 themselves. 6 Q Now, you -- the truth is, isn't it, Mr. Prince, 7 that you and Mr. Minton and Ms. Brooks, the A team, had a 8 ball with regard to all this picketing you-all participate 9 in over the last four years? 10 A I'm sorry, I hardly can agree to that, 11 Mr. Weinberg. I wouldn't call it a ball. 12 Q You had a lot of fun doing it, wouldn't you say? 13 A I wouldn't say that either, Mr. Weinberg. 14 Q You remember the first time that you went to New 15 Hampshire and -- and -- and encountered picketing in New 16 Hampshire? 17 A Yes, when Scientologists came in and picketed 18 Mr. Minton's home. 19 Q Right. And that was on Mr. Minton's -- that was 20 on Ms. Brooks' harassment time line. Right? 21 A It very well could have been. Sure. 22 Q And do you remember that you were there with 23 Mr. Minton and that you-all were laughing and giggling and 24 making fun of the Scientologists, the few that came by in 25 the cars? You called it a drive-by -- Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 673 1 A The picketers, yes, it was amusing because the 2 Scientologists came by and stood in the road with their 3 signs, and it is quite a narrow road up in New Hampshire, 4 there aren't sidewalks where Mr. Minton lives. So a state 5 trooper came and asked them not to stand in the road because 6 it was dangerous. It was actually kind of a blind curve by 7 Mr. Minton's house that makes it dangerous, being there are 8 no sidewalks. 9 And what was particularly amusing about what the 10 Scientologists resorted to at that point is that they -- 11 Mmm -- went around and pulled their cars way back, then took 12 their picket signs out the window, because they were too big 13 to stick through the window, and they held them outside of 14 the car and drove back and forth. I thought that was pretty 15 pathetic. 16 Q And you and Mr. Minton had anti-Scientology signs, 17 correct? 18 A Mr. Minton had signs. 19 Q You did, too? 20 A No. I never owned a picket sign myself. 21 Q You never held a picket sign? 22 A I never owned -- 23 Q I didn't ask you whether you owned it. 24 A I'm sorry. 25 Q You had a sign. There were signs there that you Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 674 1 and Mr. Minton had, correct? Anti-Scientology signs? 2 A That may or may not be correct. I don't 3 specifically recall. 4 Q All right. Do you remember doing a posting with 5 regard to that incident that appears on the harassment time 6 line? 7 A I do. But -- but, Mr. Weinberg, I have to say 8 this because, you know, you selectively are taking 9 paragraphs out of these things and you are painting a 10 picture here. 11 But really what this is about is -- this last 12 thing you handed me is about trying to help these people. 13 I'm telling the story about something that happened to Marty 14 Rathbun, something that might have had a psychological 15 impact on him that he would need help resolving. 16 Q But that wasn't my question. All my question was, 17 you did another posting about this incident which appears on 18 Mr. Minton's harassment time line in front of his house in 19 1998. Correct? 20 A You know, I need that time line right here. I 21 mean, I'm saying it's possible. But if you want to pull it 22 out, you want to show me what you're talking about, I think 23 I can answer the question better. 24 Thank you. 25 MR. WEINBERG: Marked as 222. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 675 1 BY MR. WEINBERG: 2 Q You can identify this as your posting, can you 3 not, Mr. Prince? 4 A Yes. 5 Q And in the second paragraph you say, "Bob and 6 Jesse quickly helped with the pilot and started bullbaiting 7 the protesters." 8 When you say bullbaiting, that would suggest that 9 you were, what, holding signs or doing something back? 10 A No. Bullbaiting is a term that is used in 11 Scientology specifically to designate some of their training 12 routines. The training routines are called TRs; TRs for 13 short. 14 Part of the training routine is to be able to sit 15 across from a person without flinching and without moving 16 when the person makes gestures or tries to do something 17 shocking; in other words, this is a routine to train you to 18 keep your countenance during an adverse commission, I guess. 19 Q In here you said, "We had great fun"? 20 A Correct. 21 Q Now, do you know why this appeared on the 22 harassment time line if it was so much fun? 23 A Well, you haven't shown me that -- and I have 24 asked you, too, to show me on the time line. So I can't 25 answer these questions -- you know, you are referring to Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 676 1 something that I don't have in front of me. I can't see it. 2 Q I thought from the testimony yesterday that you 3 had reviewed the time line pretty closely? 4 THE COURT: Well, believe me, he has. It's a 5 very long thing. I think it's a fair request. If 6 you want him to specifically note whether it is on 7 the time line or not, show him the time line. 8 MR. WEINBERG: I will. 9 THE COURT: My recollection is that document 10 was extremely long. 11 MR. DANDAR: It is. And, Judge, I object to 12 222 because there has definitely been editing done. 13 Right after "barbecue" and before the word "soup," 14 something is taken out. 15 MR. WEINBERG: No, it is not. You knew exactly 16 what it is. 17 THE WITNESS: Where is that at? 18 MR. DANDAR: Where it said, "You invited Minton 19 for barbecue," after "barbecue" there is a blank, 20 then there is "soup." 21 THE COURT: 222, you are talking about? 22 MR. DANDAR: Yes. Right here. 23 THE WITNESS: Second paragraph? Oh, yes, you 24 are right. You are right. It has been edited. 25 Something has been deleted from there. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 677 1 BY MR. WEINBERG: 2 Q What was there? Because we didn't edit anything. 3 A Yes, maybe you didn't, but your client did. And I 4 know specifically why. 5 What it said, "We were having BT and cluster 6 soup." BT is part of the secret cosmology of the upper 7 levels of Scientology. So this has been, in fact, edited. 8 MR. DANDAR: I object to it. It is an altered 9 document. 10 MR. WEINBERG: Are you testifying, first of 11 all? 12 MR. DANDAR: I'm objecting to it based on 13 Mr. Prince's testimony. It's an altered document by 14 the defendant. 15 MR. WEINBERG: He identified it before, your 16 Honor. 17 THE COURT: Well, Mr. Dandar just indicated 18 that it had been altered. And so if it now -- I'll 19 ask you, Mr. Prince, is that the original document, 20 or has it been altered? 21 THE WITNESS: Yes, your Honor, this has been 22 altered. This is not the original. 23 THE COURT: If you have one that has not been 24 altered, then it will be admissible. 25 MR. WEINBERG: First of all, we didn't alter Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 678 1 anything. 2 THE COURT: I didn't say you did. But if -- I 3 mean, I'm happy to write in the original what was 4 there if Mr. Prince remembers it and everybody 5 agrees. 6 BY MR. WEINBERG: 7 Q Do you remember what was there? 8 A I remember exactly what was there. It says we 9 were having barbecue BTs and cluster soup. “BTs” and 10 “clusters” are words Scientologists aren't allowed to use 11 outside of Scientology. 12 Q So it's a derogatory thing? 13 A No, there is nothing derogatory about BTs and 14 clusters. This is a reality – something they believe in. 15 Q Well, I -- 16 A But they are sensitive to it, so they altered the 17 document. 18 MR. DANDAR: And I would object. If there is 19 any more altered documents, that they not attempt to 20 use them, or tell you in advance. 21 THE COURT: You just heard counsel say he did 22 not know or believe it had been altered. So be 23 careful, though, when you look at your documents. 24 That does look like something is missing from there. 25 But I do know on my own E-Mails sometimes they Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 679 1 all get askew and don't seem to line up right. I 2 was on the Florida Supreme Court website looking up 3 stuff on the death penalty cases. And all of a 4 sudden they go and they just stop. So you can't 5 tell by looking. 6 MR. DANDAR: But this one -- 7 THE COURT: That one does appear to be where 8 there is something clearly missing. So -- 9 MR. WEINBERG: It obviously was not what I was 10 focusing on, BT and cluster soup. But with the 11 record indicating what Mr. Prince was saying was 12 there, I offer the exhibit. 13 THE COURT: Take the original back and write it 14 in. 15 MR. WEINBERG: Sure. 16 THE COURT: And ask Mr. Prince if that is what 17 he recalls it said and, if so, then we can admit it 18 with that -- 19 MR. WEINBERG: I'll let him write it because I 20 don't know -- I assume how to spell it but I'm not 21 sure how to spell it. 22 THE COURT: BT , is that like two initials. 23 THE WITNESS: Yes. 24 BY MR. WEINBERG: 25 Q Here. Do it like this. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 680 1 THE COURT: Everybody make notations on your 2 copies. Cluster is C-L-U-S-T-E-R. 3 THE WITNESS: Yes, your Honor. 4 MR. WEINBERG: Okay. And the original has “BT” 5 and that he wrote in. 6 THE COURT: Okay. That will be admitted. 7 BY MR. WEINBERG: 8 Q Now, you remember that at this -- 9 A Excuse me. 10 Q I wanted to show you the harassment time line. 11 Let me show you what has been previously marked as the 12 harassment time line, the "Time Line of Scientology 13 Harassment of Robert Minton and Colleagues." 14 I show you the entry for September 7, 1998. It 15 says: "Scientologists picketed Mr. Minton's home in New 16 Hampshire again but it was done in a car with picket signs 17 held out of the car window." 18 A Correct. 19 Q So that was the incident, right? 20 A Yes. 21 Q Now, I want to play this. This is that -- you 22 remember you-all videoed this? 23 A I don't remember videoing the incident, but let's 24 see what you have got. 25 Here is your pen, by the way -- Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 681 1 ______________________________________ 2 (WHEREUPON, the video was played.) 3 "Don't block her sign now, Jesse. I've gotta get 4 a picture of that good sign. 5 "Okay. Let me put mine up. 6 "Okay, yeah. 7 "Hey, Maureen, just out here having a little chat. 8 So did you see that last -- 9 "(Inaudible.) I don't know. All I can say is 10 when I was in your position, there was a lot of -- 11 "That you're a staunch Scientologist. And it's 12 dangerous for you to believe otherwise because you'd be 13 wrong." 14 ______________________________________ 15 BY MR. WEINBERG: 16 Q Those are Mr. Minton's signs? 17 A Correct. 18 ______________________________________ 19 "Drive-by pickets. That's cool." 20 ______________________________________ 21 MR. DANDAR: Could we clarify the people in the 22 car are Scientologists? 23 BY MR. WEINBERG: 24 Q They are, aren't they, Mr. Prince? 25 A They are. OSA personnel. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 682 1 ______________________________________ 2 "Damn dumb asses. I got 'em. See, what they 3 need, what they need is like a -- what they need -- what 4 they need is a chain -- I mean a long line of cars. 5 "They just don't seem to be able to get more than 6 two -- 7 "Yeah. 8 "-- for these little New Hampshire things. 9 "Hey, it's an hour from Boston, man. 10 "Ain't it pathetic. One person holding one sign 11 out the window. And then when they go by this way, the 12 driver can't do it so the fucking sign's over there. Oh, my 13 God. How pathetic. 14 "They must think this is having some kind of 15 terrible psychological impact. 16 "Yes, it's just entertaining as all hell. 17 "Here they come. 18 "Okay. 19 (Inaudible.) 20 "Hey, you fucking idiot. 21 "They don't have enough nerve to try to run over 22 me. 23 "Me, either. I stood there, too. I just stood in 24 the middle of the road and got 'em driving up. 25 "Look at this. This is a good one. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 683 1 "Here they come again. That's when they were 2 coming earlier. That's all I got of them so far, but the 3 two of them are good. 4 "Yeah." 5 (End of playing of the video tape.) 6 ______________________________________ 7 MR. WEINBERG: That is it? 8 BY MR. WEINBERG: 9 Q So you were having fun, you and Mr. Minton, in 10 this thing on the harassment time line? 11 A Mmm, you know, Mr. Weinberg, I think even I said 12 on that tape it was just an annoyance that they do it; 13 though it was pathetic and though it was funny, it's 14 annoying. 15 Now, you made a huge point about how harassed 16 Scientology feels about being picketed. But when these 17 people come by and picket, we're supposed to be having fun. 18 You can't have it both ways. 19 Q Well, what do you call what they were doing, by 20 the way? Do you call that harassment? Or do you call that 21 the First Amendment? 22 A They were exercising their First Amendment rights. 23 But what happened that was harassing is that Bob and I 24 didn't have a clue they were even out there until they 25 parked their cars, ran up to the door, knocked on the door Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 684 1 screaming, "Minton, Minton, Minton," then ran back to their 2 cars. This is the only way they let us know they were 3 there. 4 We are upstairs fooling around on the computers. 5 These guys are banging on the doors. We wonder, what the 6 heck. We run down. And we got the drive-by pickets going 7 on. 8 Q They didn't shout obscenities? 9 A Absolutely. "Where is your whore, Minton?" This 10 kind of thing. Absolutely. 11 Q You didn't hear that on the tape, though, did you? 12 A Well, of course not. Because what I'm speaking 13 about is when they knocked on the door, and we were way in 14 the back of the house. They wanted to make themselves 15 known. Now, what they're doing, going up and down there, 16 okay. 17 Q Now, after this, after September of 1998, was this 18 your first encounter with picketing, having signs and stuff 19 like that? 20 A It could have been. 21 Q Now, after this, for the next -- for the next four 22 years, or almost four years, Mr. Minton and you and 23 Ms. Brooks and other people affiliated with the Lisa 24 McPherson Trust did all kinds of pickets in front of 25 Scientology buildings, shouting obscenities, making threats, Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 685 1 interfering with -- with Scientologists going into their 2 buildings and the like, didn't you? 3 A That is categorically false. 4 MR. WEINBERG: Could you play the first tape, 5 please. This is May 27 -- this is again -- this is 6 the Lisa McPherson Trust. 7 ______________________________________ 8 (WHEREUPON, the video was played.) 9 "Stick this in the right place. Scientology is 10 a scam. A white meter. Fucking criminal. David 11 Miscavige is a white Jew. He will be a convicted 12 criminal." 13 (End of playing of the video tape.) 14 BY MR. WEINBERG: 15 Q Now, do you consider that harassment of the Church 16 of Scientology? That was out in front of the church in 17 Boston, wasn't it? 18 A Yes. Was I there? 19 Q I'm asking you, do you consider that harassment? 20 MR. DANDAR: Objection. He's not there. He 21 should not be asked to comment about -- 22 THE COURT: I think he can comment on that. 23 Overruled. 24 A You know, what I see there, that little snippet 25 that you showed me, I would say yes, that is a bit annoying Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 686 1 and harassing. 2 But I also suspect, because when Bob Minton would 3 go out and picket, he would just be quiet, he wouldn't say a 4 word, he would just walk up and down the street. 5 But then the OSA people would come out, Maureen 6 Garde, the person I was walking with in the previous video, 7 they would come out and start talking to Mr. Minton about 8 things from his therapy sessions. This is where the therapy 9 information started, in picketing the Boston org. And they 10 would kind of whip him into a frenzy. And the whole idea 11 was to bait Mr. Minton to make him look like an ass. 12 Well, you know, I agree everyone ended up looking 13 like an ass on some of those things, but, you know, let's 14 put this in perspective, because these little snips aren't 15 going to work. These people were specifically targeting 16 Mr. Minton to do psychological terrorism on him. 17 BY MR. WEINBERG: 18 Q Now, is it a bit annoying that Mr. Minton said 19 that L. Ron Hubbard and David Miscavige were wife beaters? 20 That is a bit annoying? 21 A And I'm sure he's annoyed because Mrs. Maureen 22 Garde started speaking to things about -- from his 23 confidential counseling sessions with Scientology. How 24 Scientology got that information, God only knows, because no 25 one will ever speak on it, will they? But that is what was Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 687 1 happening there. 2 Q And Mr. Minton, according to your testimony, was 3 quiet on his pickets? 4 A He would just be as quiet as hell. Then if he got 5 antagonized, he would start in. And I think that was known. 6 And, you know, you talk about me hating 7 Scientologists. When you saw me in that first -- 8 THE COURT: We're well past the answer to that 9 question. 10 THE WITNESS: Okay. 11 MR. WEINBERG: Play the next one, please. 12 ______________________________________ 13 (WHEREUPON, the video was played.) 14 "Reform Scientology now. Don't let David 15 Miscavige destroy Scientology. L. Ron Hubbard would 16 not approve of what David Miscavige has done. 17 "It's safe to look. It's safe to talk. Don't 18 let David Miscavige destroy the Church of 19 Scientology. Make it something you can be proud of. 20 Dump David Miscavige. Dump David Miscavige. It's 21 safe to talk. It's safe to look. Don't let David 22 Miscavige destroy Scientology. L. Ron Hubbard would 23 never approve of what Miscavige is doing. 24 (Inaudible.) 25 "Reform Scientology now. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 688 1 "Don't let the introspection rundown kill you. 2 You don't have to die in introspection rundown. You 3 don't have to let Miscavige scare you to death. 4 "Don't be afraid. 5 "Don't let Miscavige scare you out. 6 "It's okay to confront the fact that Miscavige 7 cannot handle some pressure." 8 (End of playing of the video tape.) 9 ______________________________________ 10 BY MR. WEINBERG: 11 Q You recognize that as people including Mr. Minton 12 from the Lisa McPherson Trust, right where the 13 Scientologists in Clearwater go to eat, right? That is 14 where that was, wasn't it? 15 A Yes, it was. 16 Q And that sure sounded like a direct attack on 17 David Miscavige, didn't it? 18 A Mmm, it sounded like there was definitely some 19 problems with Miscavige being voiced there. 20 Q You saw Miss Greenway there, didn't you? 21 A Yes. 22 Q You saw David Cecere from the Lisa McPherson 23 Trust? 24 A Yes. I didn't see me, though. 25 Q You were the vice-president of PR at the Lisa Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 689 1 McPherson Trust, weren't you? 2 A That is such a fabrication, it is laughable. I 3 have never been -- had anything to do with public relations, 4 period. Can't you tell? 5 Q So what was your position at the Lisa McPherson 6 Trust? 7 A I was there specifically to help people who had 8 been in -- somehow had some gripe with Scientology that they 9 wanted to make right. 10 And again I'll say it. The work that we were 11 doing at the Lisa McPherson Trust helped Scientology because 12 you had a lot of garbage in the street, people that were 13 hurt, people giving you a bad name. When we finished with 14 those people, they signed releases saying they wouldn't 15 speak disparagingly about you again, they got their money 16 and they went on their way. Okay, that part needs to be 17 told. 18 Q My only question was what was your title or 19 position in the Lisa McPherson Trust? 20 A Vice-president. 21 Q Vice-president of what? 22 A The Lisa McPherson Trust. 23 Q And what was your responsibility there? 24 A I'll say it again. 25 THE COURT: He just already said that. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 690 1 MR. WEINBERG: That is just what he said? 2 THE COURT: Yes. 3 BY MR. WEINBERG: 4 Q Now, were you referred to as the big boss at the 5 Lisa McPherson Trust? 6 A No. 7 MR. WEINBERG: Play the next one, please. 8 ______________________________________ 9 (WHEREUPON, the video was played.) 10 "Make Scientology something to be proud of. 11 Reform it now before David Miscavige ruins it. Find 12 the new leaders within your organization whom you 13 can be proud of. 14 "Stacy, why don't you try to round some of them 15 up? 16 "The Lisa McPherson Trust was established at 33 17 North Ft. Harrison Avenue in order to let the world 18 know about the abusive practices which David 19 Miscavige has caused Scientology to live by. 20 "The Lisa McPherson Trust will always be here 21 to remind you that you have a responsibility to be 22 good human beings. David Miscavige is ruining your 23 organization. 24 "Telecommunications is one of the powerful 25 things you have learned in Scientology. Use it. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 691 1 Try to use it to make the world a better place and 2 start with dumping David Miscavige. 3 "If you ever want any help from Scientology, 4 you can run to 33 North Ft. Harrison Avenue to the 5 Lisa McPherson Trust. 6 "If you remember, Lisa McPherson is the woman 7 who was held by Scientology for 17 days. 8 "The whole episode in the Church of 9 Scientology's Ft. Harrison Hotel was totally 10 out-tech. Even the state prosecutor said it was 11 totally out-tech. The whole thing was run by David 12 Miscavige. David Miscavige is responsible for that 13 woman's death. 14 "Remember, David Miscavige is the one who 15 performed the out-tech on Lisa McPherson. 16 "Remember, David Miscavige was responsible for 17 the out-tech, out-tech handling of Lisa McPherson. 18 She died after 17 days in captivity here. 19 "It was totally out-tech and you know it. You 20 can look and smile. 21 "David Miscavige pulled the plug on Lisa. He 22 pulled the plug on Hubbard's tech. It's time to 23 face reality. Reform Scientology or it will be 24 destroyed by David Miscavige." 25 (End of playing of the video tape.) Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 692 1 ______________________________________ 2 BY MR. WEINBERG: 3 Q Now, what was the reason that the Lisa McPherson 4 Trust documented all these pickets by taking videos like 5 this? 6 A Mmm, I think the purpose of the Lisa McPherson 7 Trust always having the video when in close proximity to 8 Scientology is the same reason that -- for the same reason 9 that happened to Mr. Minton when David Howe (phonetic) and 10 another staff member -- I think that was a staff member that 11 attacked him. I personally took him to the hospital. He 12 just raced him, no one is looking, boom. 13 So it became routine to take a video camera, in 14 case something did happen that was truly criminal, that it 15 could be documented. That was the purpose. 16 Q But it was for evidentiary purposes? 17 A Correct. 18 Q It wasn't for posterity? 19 A Correct. 20 Q I mean, wasn't this what the Lisa McPherson Trust 21 was about -- let me finish my question -- to try to get rid 22 of David Miscavige and to terrorize, using your word now, 23 the Church of Scientology? 24 A I -- I think Mr. Minton was very clear on what the 25 Lisa McPherson Trust was for. And I'm glad you showed that Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 693 1 video, because he made it clear he wasn't out to destroy 2 Scientology, make Scientology go away, as you have, you 3 know, suggested earlier. He wanted it to reform. He wanted 4 the criminal activities to stop. 5 Why does he pick David Miscavige? I think we need 6 to talk about it. Because you know why? He's the man that 7 has the private investigators do what they do. He's the one 8 that -- that instigates these vicious attacks against 9 individuals who have any disparaging thing to say about 10 Scientology. 11 Why does Mr. Minton mention him? Because he knows 12 he's the person that can change it. Just like that letter 13 that was turned into evidence concerning Bernie McCabe. 14 He's the person that can do it. If anyone can do it, 15 Mr. Miscavige can do it. 16 Q Right. And you accused Mr. Miscavige of murder in 17 your affidavit, didn't you? 18 A I accused of -- Mr. Miscavige of letting her die? 19 Q Of intentionally letting her die? 20 A Letting her die. 21 Q Intentionally? 22 THE COURT: We'll not get anywhere. The 23 document speaks for itself. 24 MR. WEINBERG: You are right. 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 694 1 BY MR. WEINBERG: 2 Q You suggested, stated, in your affidavit, that a 3 decision was made, an intentional premeditated decision, to 4 let her die? 5 A Correct. 6 Q This is the same man that you shouted obscenities 7 about, it's the same man we are watching videos of Mr. 8 Minton and others stand up, asking to be deposed or thrown 9 out of position, right? 10 A It's the same man I audited. It's the same man I 11 have been friends with many years. It's the same man I have 12 done training with. It's the same man I helped myself 13 establish and build Scientology for many years. So add that 14 into the equation, too. 15 Q You think he would call you his friend? 16 A I think if David and I sat down and talked, he 17 would -- 18 THE COURT: I have heard this question and I 19 have heard this answer at least twice. 20 MR. WEINBERG: Thank you. 21 BY MR. WEINBERG: 22 Q Now, when Mr. Minton said the words "Out-tech" 23 that is something that means something to a Scientologist, 24 correct? 25 A Correct. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 695 1 Q I mean, Mr. Minton, prior to getting involved with 2 you -- 3 THE COURT: Counselor, it is getting pretty bad 4 to me because I understood it. 5 MR. WEINBERG: But -- all right. 6 BY MR. WEINBERG: 7 Q A Scientologist, or a judge that sat in a hearing 8 for 28 days. 9 THE COURT: There you go. 10 BY MR. WEINBERG: 11 Q That is not something Mr. Minton or any of us, 12 having not been exposed to Scientology before, would 13 understand, correct? 14 A Yes. 15 Q And to be out -- out to accuse the ecclesiastical 16 leader of being out-tech is about as -- about as serious and 17 severe an accusation as you could possibly make against 18 David Miscavige, isn't it? 19 A Mmm, Mr. Weinberg, my answer is if the shoe fits, 20 wear it. 21 Q Just answer that question. 22 A I did. If the shoe fits, wear it. 23 THE COURT: No, he wants to know if that is a 24 serious accusation to make to other Scientologists 25 about their ecclesiastical head. Is that a bad Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 696 1 thing to the head of Scientology to be out-tech. 2 THE WITNESS: Yes, it is. 3 THE COURT: To another Scientologist, those 4 folks seeing that demonstration, if they believed 5 that, would not think very highly of their leader? 6 THE WITNESS: Correct. 7 BY MR. WEINBERG: 8 Q And would you not -- from looking at that video or 9 the other videos that you have seen so far, it doesn't look 10 like any of the Scientologists are having a lot of fun at 11 your demonstrations, correct? 12 A You know, you have only shown me specifically 13 Mr. Minton. You haven't shown me what the Scientologists 14 are doing or not doing, Mr. Weinberg. 15 Q Well, in that video we just showed, it was -- 16 A It was going back and forth. 17 THE COURT: You know what, the deal is we are 18 showing this for -- 19 MR. WEINBERG: That is correct. 20 Could you play the next one, please. 21 ______________________________________ 22 (WHEREUPON, the video was played.) 23 "Communicate to David Miscavige that he's 24 fired. 25 "Remember Lisa McPherson. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 697 1 "When you're eating, remember Lisa at her last 2 meal in December of '95, held captive by the Church 3 of Scientology leader, David Miscavige. 4 (Inaudible.) 5 "What is not safe for you is to stand there and 6 do nothing. Tell David Miscavige he's wrong. Tell 7 him that L. Ron Hubbard would never approve of what 8 he is doing to destroy your church. 9 "PK, PK, don't run away." 10 (End of playing of the video tape.) 11 ______________________________________ 12 BY MR. WEINBERG: 13 Q Does it look, in that video -- I mean, and others 14 that we've seen -- that Mr. Minton is terrorized, harassed 15 or anything like that? 16 A Mmm, it looks like Mr. Minton was picketing, to 17 me. 18 Q Now -- 19 ______________________________________ 20 (WHEREUPON, the video was played.) 21 "Okay, are we going to do the locks? 22 "But the -- are we going to do the alarms or --" 23 (Inaudible.) 24 (End of playing of the video tape.) 25 ______________________________________ Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 698 1 BY MR. WEINBERG: 2 Q You were just having a big time, you and 3 Ms. Greenway? 4 A You know, that is an edited video you have there. 5 It is -- there is obvious editing there, so I would be 6 hard-pressed to draw that conclusion. 7 Q When it started, it started like all of the 8 pickets started inside the offices of the LMT, correct? 9 A That is a mischaracterization of how pickets 10 started because every picket did not start in the Lisa 11 McPherson Trust. Other people picketed the Ft. Harrison 12 that weren't associated with the Lisa McPherson Trust or 13 employees of the LMT -- Lisa McPherson Trust. 14 Q That clip from the LMT film library, that one 15 started in the LMT building, didn't it? 16 A I don't know if it started or finished there 17 because you have shown me one tiny segment. So, you know, 18 if I could have some perspective and see the whole thing, I 19 would be able to comment more accurately. 20 Q Now, the LMT -- literally at times these pickets 21 were intended to literally shut down Clearwater around where 22 you-all were picketing, right? 23 A No. 24 MR. WEINBERG: Play that one, please. 25 ______________________________________ Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 699 1 (WHEREUPON, the video was played.) 2 "Last year, we were all over the place in a 3 clump. We shut down here, we shut down here, we 4 shut down there. We had Flag shut down for the 5 whole day, anyway. This year we spread out in 6 strategic spots and shut down the whole city. 7 "Frank Oliver came and caused the last breach. 8 So far about two hours now they can't hardly move 9 anybody any way. They can pick up people from Flag 10 but they can't bring them in because they have to 11 bring them in there, and they can't do it." 12 (End of playing of the video tape.) 13 _______________________________________ 14 BY MR. WEINBERG: 15 Q That is somebody from the LMT? 16 A Absolutely not. 17 Q Who is that? 18 A Greg Hagglund. He lives in Canada. 19 Q And he was down here for the picket in December? 20 A Looking at that date of that, he was down for the 21 picket and vigil. People come from all over the United 22 States and even Europe for that. They were doing that long 23 before the Lisa McPherson Trust ever existed or it was here 24 in Clearwater. So, you know, it would be a real bad stretch 25 to think that, you know, he's working at the trust because Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 700 1 he's picketing. 2 Q Well, is there a particular reason why the trust 3 had that tape in its film library? 4 A Maybe someone videotaped it and gave it to the 5 trust, Mr. Weinberg. 6 Q Well, who was the videotaper for the trust? 7 A Mark Bunker. 8 ______________________________________ 9 (WHEREUPON, the video was played.) 10 "Remember Lisa McPherson. Okay, let's go. 11 (Inaudible.) 12 "-- is one of our old friends. 13 "Yes. Some other friends from Germany, too. 14 "That is a good one, too. 15 "Where else would you like --" 16 (Inaudible.) 17 (End of playing of the video tape.) 18 ______________________________________ 19 BY MR. WEINBERG: 20 Q Those are all people from the Lisa McPherson 21 Trust, weren't they? 22 A False. 23 Q Oh, Miss Caberta was from Germany, your guest over 24 here? 25 A Ms. Caberta was here on vacation. Mrs. Caberta. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 701 1 And if you will recall, you yourself earlier said she's 2 employed by the German government. So, you know, she's not 3 LMT. She's just like you said, employed by the German 4 government. 5 Q This was an LMT-sponsored picket in front of the 6 Ft. Harrison Hotel? 7 A LMT has never, to my knowledge, sponsored a 8 picket. 9 Q Is there a particular reason why Mr. Merrett was 10 at that picket? 11 A I believe Mr. Merrett was at the picket to make 12 sure that nothing happened, there were no altercations, no 13 scuffles, no -- you know, you'll notice this, people, for 14 the most part, are just silently walking up and down the 15 street. They are not screaming at Scientology itself or 16 yelling at Scientologists; they are exercising their 17 constitutional right to protest. 18 Q Do you think it might be somewhat harassing to 19 the -- on the doorstep of the mecca of Scientologists with 20 signs saying "Blood of Lisa McPherson on your hands" and 21 things like that? 22 A You know, I can see where someone could draw that 23 inference or conclusion. But the inference and conclusion I 24 draw is people were exercising their constitutional right. 25 If it was even a civil crime, they would have been sued out Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 702 1 of existence. 2 Q Do you remember that the Lisa McPherson Trust -- 3 people documented by Lisa McPherson Trust video picketed in 4 front of the Ft. Harrison Hotel when a Hindu wedding was 5 going on? A Hindu wedding? 6 A No, I was not there. I know nothing about it. 7 Q As your position as the VP of the Lisa McPherson 8 Trust, you don't remember that one? 9 A Correct. 10 MR. WEINBERG: Why don't we show that. 11 THE WITNESS: Was I present here? 12 ______________________________________ 13 (WHEREUPON, the video was played.) 14 "Well, Jesus, that is one thing Scientology didn't 15 believe in or any other religion, isn't that right, guys? 16 Isn't that right? Isn't that right? That is all -- let's 17 let all of the Nazis come out. 18 "People are trying to have a wedding, sir. 19 "What is that? 20 "Hey, this is fine. 21 "They're just trying to have a wedding. They are 22 not -- 23 "Listen, it's not my fault they got married here. 24 "Come on now. 25 "This is a public sidewalk, buddy, so don't start Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 703 1 pushing. 2 "This is not -- (inaudible). 3 "This is a public sidewalk. Let's get out of the 4 way. It is still a public sidewalk. Okay? 5 "When you get out of Scientology, your luck 6 will -- 7 (Inaudible.) 8 "Let's go. Let's go. 9 "Let's go. 10 "Come on." 11 (End of playing of the video tape.) 12 ______________________________________ 13 BY MR. WEINBERG: 14 Q Why did the LMT put that in its film library? 15 A I think that every -- and I'm not sure if this is 16 not Mr. Mark Bunker's film library that you are referring 17 to -- but, you know, we're -- we're looking at here your two 18 star witnesses. You are showing me videos of your witnesses 19 that you have used in this hearing to testify for you. What 20 are we doing here? 21 Q I think you said that this is the most harassed 22 person you have ever seen. Does it look like Mr. Minton is 23 the most harassed person you have ever seen when he's 24 standing there with a sign with skulls on it in front of the 25 Ft. Harrison -- Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 704 1 THE COURT: Don't -- 2 MR. WEINBERG: I'm sorry. 3 THE COURT: -- raise your voice up to this 4 witness and start approaching him. 5 MR. WEINBERG: I'm sorry. 6 THE COURT: I won't have it. And I'm not going 7 to remind you again. 8 BY MR. WEINBERG: 9 Q With a sign with skulls on it, interrupting a 10 Hindu wedding? 11 A Mr. Weinberg, I agree with you what happened 12 there -- what happened was extremely inappropriate. And I 13 don't agree with it. And you didn't see me there. 14 Q I'll show you one you are at, Mr. Prince. 15 By the way, before you play that, that tape was 16 done -- the one we just played was done in -- in September 17 of 2000. 18 You were full-time at the Lisa McPherson Trust, 19 correct? 20 A That is possible, yes. 21 Q Not possible. That is correct? 22 A I said it's possible. 23 Q Why do you say it's possible? I mean -- 24 A Because I'm not sure when I made that transition 25 from -- I'll explain it to you, I'm not trying to be coy Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 705 1 here, but there came a point in time when my work with 2 Mr. Dandar involved doing a bunch of depositions of 3 Scientology staff members or Scientologists or whatever and 4 we worked together quite a bit then. 5 But then there came a period of time when it was 6 time for the medical experts. Those people are the experts. 7 He certainly didn't need me there. So there came a point in 8 time when I started working at the Lisa McPherson Trust. 9 Q In September of 2000 when that took place, you 10 were on the payroll of the Lisa McPherson Trust, correct? 11 A It is possible, yes. 12 ______________________________________ 13 (WHEREUPON, the video was played.) 14 "Jesse is -- this is -- Jesse, show him what 15 you're going to do if they come at you. 16 "Drop and fall. That is all. I'm going to fall 17 down. 18 "Hey -- 19 "You know what (inaudible). 20 "That is a good idea. 21 "Full resistance, that is our motto. 22 "How are you going to do it? 23 "Just carry the sign. 24 "Oh, my God. 25 "Kind of like the Three Stooges. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 706 1 "The St. Pete Police. 2 "Yes, I told them I would be there by quarter to 3 seven. 4 "Oh, God. 5 "Let's do this. 6 "Guys, remember what we all agree with. We're all 7 staying together. 8 "Yes, boss. 9 (Inaudible.) 10 "Uh-huh. Uh-huh. Okay, well -- Mmm, no." 11 (End of playing of the video tape.) 12 ______________________________________ 13 BY MR. WEINBERG: 14 Q Now, that is one of your six pickets? 15 A Rhetorical. 16 Q Excuse me? 17 A That is one of the six pickets I have probably 18 been in. 19 Q And in that video we saw Patricia Greenway, 20 correct, who is in the audience, right? 21 A Show it to me again. I missed that. 22 THE COURT: Yes, she was there. 23 THE WITNESS: Okay. I'll take your word. 24 BY MR. WEINBERG: 25 Q Peter Alexander, who testified in this hearing? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 707 1 THE COURT: I don't know if he was there or 2 not. 3 MR. WEINBERG: He was. 4 THE COURT: I didn't recognize him, but -- 5 BY MR. WEINBERG: 6 Q The gentleman, sort of young guy in the pink or 7 red shirt, that was Graham Berry, correct? 8 A Correct. 9 Q The lawyer from LA? 10 A Correct. 11 Q Now, your sign, "Mafia Cult"? 12 A Correct. 13 Q And that was -- 14 A In relationship to the black operations that are 15 run out of OSA. 16 Q And you were picketing, you walked from the LMT -- 17 this was an LMT operation, wasn't it? That is where you-all 18 left from, from the LMT? 19 A Yes. 20 Q And at that point, you were full-time at the LMT? 21 A I -- I'll stipulate to that, sure. 22 Q Except you were still working for Mr. Dandar, you 23 were still doing stuff on the Lisa McPherson case, weren't 24 you? 25 A Well, you know, as I said, Mr. Weinberg, there Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 708 1 came a time when Mr. Dandar was solely doing medical 2 experts. There was certainly no need for me to sit there 3 through that. 4 MR. WEINBERG: One second, your Honor. 5 BY MR. WEINBERG: 6 Q Now, you, Mr. Dandar and a number of other people 7 from the LMT were at the closing when Mr. Minton closed on 8 the purchase of the building either at the -- at the 9 beginning -- January 5 of 2000, is that right? 10 A I believe that is correct. 11 Q And Mr. Dandar was -- and you and Mr. Minton and 12 Ms. Brooks were very enthusiastic about the LMT and how the 13 LMT was going to -- to operate. Correct? 14 A Yes. 15 Q And Ms. Liebreich was very enthusiastic about the 16 LMT opening, correct? 17 A I don't think Mrs. Liebreich was there. 18 Q But do you remember that the first phone call that 19 was made was made to Ms. Liebreich, and you talked to her, 20 among other people? 21 A I think I remember something about that, yes. 22 Q And she was very enthusiastic about that. Right? 23 A She was very happy and proud that the last wishes 24 of Fannie McPherson were actually taking effect, which was 25 to expose any deceptive and abusive processes by Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 709 1 Scientology, you know. 2 Mr. Minton is -- just wants reform, tired of 3 people calling, tired of people saying, "Can you please 4 help." 5 Q Your testimony, I believe, was -- and correct me 6 if I'm wrong -- that you never met with Mr. Dandar for any 7 purpose -- for any meeting type purpose at the LMT. Is that 8 right? 9 A Correct. 10 Q Now, do you remember at this opening that -- at 11 this closing where, in essence, the LMT was opening, that 12 you described -- or someone described what your position and 13 responsibility was going to be at the LMT? 14 A I don't recall it specifically, Mr. Weinberg. 15 Q And you deny it was in charge of PR, right? 16 A Correct. 17 MR. WEINBERG: If you could play that, please. 18 This is another video from the LMT. 19 ______________________________________ 20 (WHEREUPON, the video was played.) 21 "Ken, I'm sorry there's no more chairs. 22 "It is okay. 23 "Sign first -- (inaudible). 24 "You want to sit down? Here is the -- these 25 are the -- (inaudible). Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 710 1 "Did you bring the property insurance papers? 2 "Of course not. 3 "You didn't? 4 (Inaudible.) 5 "You mean the balance, it's everything you did 6 fax me yesterday. 7 (Inaudible). 8 "The insurance papers are the closing paper for 9 the mortgage. 10 "Yeah. Right. Right. 11 (Inaudible.) 12 "That is okay. That is okay. 13 "It's just that we don't have the check for 14 him -- or, we have the check but -- (inaudible). 15 "How are we going to do it? How are you going 16 to do it? 17 (Inaudible.) 18 "No, I'll just tell you to send a check and how 19 much it is. (Inaudible.) It's a binder. 20 (Inaudible.) 21 "If Scott has a fax machine I can fax it to 22 him. 23 "Hang on one second. Okay? 24 "Yes. 25 "Okay." Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 711 1 ______________________________________ 2 BY MR. WEINBERG: 3 Q Is that Tom Tobin from the St. Pete Times? 4 A I believe it is. 5 ______________________________________ 6 "This is Steve Mitchell. This is Jesse Prince. 7 "Nice to meet you, Jesse. 8 "Nice to meet you. 9 "He's an expert on Scientology in the Lisa 10 McPherson case. He's going to be also working at the trust. 11 "Oh. Terrific. 12 (Inaudible.) 13 "So he has an idea of what we're dealing with. 14 Big time, right? 15 "Big time, Bobby. This is too cool. 16 "Jesse, what are you going to do with this 17 organization? 18 "Make it as successful as possible. 19 "I mean, what's your job or what -- do you have 20 functions or duties or -- 21 "I'm on the board of directors. And I'm going to 22 just, you know, be here with the organization, get it 23 through its initial phase of establishing itself, and run 24 around and do public relations. 25 "Oh, really. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 712 1 "Yes. 2 "He's also an expert on the Lisa McPherson case so 3 he's going to be spending a lot of time with Ken Dandar so 4 he'll be --" 5 (Inaudible.) 6 "He's been working, you know, intimately with Ken 7 on this case for a long time. 8 "Oh. 9 (Inaudible.) 10 "You mean, does he own the building now? 11 "Thank you very much. Thank you. Scott. 12 "Thank you. 13 "Thank you very much. I can't tell you how much I 14 appreciate this. 15 "I wish you the best. I hope you do well with 16 this. 17 "Thank you. 18 "Scott's been under a lot of pressure, I'm sure. 19 "Congratulations. 20 "Thank you. 21 "Jesse. 22 "Hey, Ken? 23 "Hey, Ken? 24 "So anybody want to open that champagne? 25 (Inaudible.) Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 713 1 "Ken, your comments? 2 "Well, I think this is a good day for downtown 3 Clearwater. 4 "Hi, Mike. How is it going? 5 "Happy New Year. 6 "We just closed on the building. 7 "Okay. Call me. 8 "I have a binder in my office." 9 (End of playing of the video tape.) 10 ______________________________________ 11 MR. DANDAR: Could we have a stipulation that 12 was edited by the defense? 13 MR. WEINBERG: I mean -- 14 THE COURT: I don't know if it was or not. 15 MR. WEINBERG: I mean, Mr. Bunker edited a lot 16 of these tapes before he ever gave them to us. I 17 mean -- 18 MR. DANDAR: Well, whatever. 19 MR. WEINBERG: I mean -- 20 THE COURT: All I can say, Counselor, it is 21 available for you to get a copy of, so -- 22 MR. DANDAR: I know. 23 BY MR. WEINBERG: 24 Q Now, what was the Lisa McPherson trial consultant 25 and the Lisa McPherson case lawyer doing at the closing of Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 714 1 the LMT building? 2 A It looks like they were partaking in the 3 festivities, to me. 4 Q It does to me, too, Mr. Prince. 5 A Yeah. 6 Q Now, when Ms. Brooks said that you were going to 7 be doing public relations, was your first job to get Tom 8 Tobin from the St. Pete Times there? 9 A You know, I think that is a leap in logic. And I 10 think the person that actually said doing public relations 11 stuff was me. I don't think it was Ms. Brooks. 12 Q All right, I stand corrected. When you said you 13 were doing public relations, what did you mean? 14 A I think that that was just an offhand comment. 15 And I didn't even know what I meant. Maybe I had some 16 intention on doing something public relations-wise. 17 But what factually ended up happening is once the 18 door opened, the phones started ringing. And as I 19 mentioned, you know, getting through the initial 20 establishment part, to find out exactly what our role is 21 going to be, it simply turned into servicing current and 22 ex-Scientology members. 23 Q The way you got your message out was to carry 24 signs and picket in front of the Church of Scientology? 25 A That was the one thing that was done. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 715 1 Q And -- but at this time when this started in 2 January 5 of 2000, you were in charge of public relations 3 but you were being paid by Mr. Dandar to be a so-called 4 expert in the Lisa McPherson case. Correct? 5 A That is totally incorrect. There was no public 6 relations. I was not doing public relations, orchestrating 7 public relations, media contact. 8 Mr. Weinberg, if you have shown anything with the 9 indiscretion I have used, public relations is not anything 10 that I would even pretend to be versed in, so, you know, 11 let's move on. 12 THE COURT: I'm going to tolerate about one 13 more of these, then I can't stand any more for the 14 day. I still do not know why we're playing all of 15 these, but -- 16 MR. WEINBERG: I can explain. 17 THE COURT: I'll let you do that in closing 18 argument, but I can only stand one more today, so 19 play it and -- 20 MR. WEINBERG: I'll play one more and it will 21 be this one. 22 THE COURT: All right. 23 MR. WEINBERG: December 2, picket across from 24 the Ft. Harrison. 25 I want you to look for Mr. Dandar here. All Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 716 1 right? 2 THE WITNESS: Okay. All right. 3 THE COURT: What is the date again, Counselor? 4 MR. WEINBERG: December 2, 2000. 5 THE WITNESS: Was I at this picket? 6 (WHEREUPON, the video was played. No audio 7 available.) 8 BY MR. WEINBERG: 9 Q You recognize the person with the sign was Frank 10 Oliver? 11 A Yes. 12 Q You recognize Teresa Summers? She testified in 13 this case. 14 A Yes. 15 Q You recognize yourself? 16 A Yes. 17 Q You recognize Mr. Merrett? 18 A Yes. 19 Q You recognize Mr. Minton? 20 A Yes. 21 Q You recognize Mr. Dandar. Correct? 22 A Yes. 23 Q And that was in front of the Ft. Harrison during a 24 picket, wasn't it? 25 THE COURT: I didn't see any signs except Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 717 1 one -- I did not see what I would classify as a 2 picket. 3 A There was no picket. And I remember this 4 incident, if you'll let me explain it to you. 5 Bob Minton had come into town and Ken needed to 6 talk to him or see him for something. Mr. Dandar simply 7 stopped by. Mr. Dandar was not a part of any picket or 8 doing anything. He simply knew where Mr. Minton was going 9 to be, he came there, spoke with him and left. 10 BY MR. WEINBERG: 11 Q So what were you-all doing there? 12 THE COURT: I saw folks across the street, 13 Counsel, that had signs, then somebody said hi, went 14 across the street. That is where Mr. Dandar was. 15 The sign was down. The only one person that had it, 16 they were talking, then somebody put a sign up and 17 went off like there was something else going on 18 someplace else. 19 I don't think it would be fair to classify what 20 Mr. Dandar was in was a picket. I could not tell 21 they were in front of any hotel, either. 22 BY MR. WEINBERG: 23 Q Well, you recognize that was across from the Ft. 24 Harrison? 25 A No, I do not. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 718 1 THE COURT: I don't know where it was because I 2 couldn't tell. It looked like a street corner. It 3 might have been. I don't recognize that. 4 MR. DANDAR: I can tell you, Judge. It was 5 catty-corner across the street from the Ft. 6 Harrison. These people with signs who were across 7 the street from me, across the street from the Ft. 8 Harrison, were standing in front of the new Super 9 Power building. But I wasn't part of any picket. 10 That is right. 11 BY MR. WEINBERG: 12 Q Now, was Mr. Merrett part of the picket? 13 A No, he was not. 14 Q Were you? 15 A No, I was not. 16 Q So you had been -- so all these LMT people were 17 sort of off to the side, and there were other LMT people 18 that were holding signs? 19 A You know, again, Counselor, I'm not trying to be 20 difficult here. You are showing snippets and you are 21 drawing conclusions. The conclusion that I see from this 22 snippet is we are simply standing there having a 23 conversation. No one but no one is picketing. 24 THE COURT: Looks like there was getting ready 25 to be a picket. There were people with signs, but Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 719 1 when they saw Dandar, it looks like somebody waved, 2 walked across the street, the guy that had the sign, 3 whoever that was, the one, put his sign down. When 4 he picked up the sign, he went walking off to where 5 I would presume a picket was going on. But those 6 other folks were across the street that must have 7 been going for a picket, I'm guessing. 8 MR. WEINBERG: You said that was the last one 9 you wanted to see. 10 THE COURT: That is absolutely the last one I 11 want to see. 12 It is 5 o'clock. We're done for the day. 13 We'll see you at 9~o'clock tomorrow. 14 MR. WEINBERG: Thank you. Have a good night. 15 (WHEREUPON, Court stands in recess at 5 16 o'clock.) 17 _____________________________________ 18 19 20 21 22 23 24 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 720 1 REPORTER'S CERTIFICATE 2 3 STATE OF FLORIDA ) 4 COUNTY OF PINELLAS ) 5 I, LYNNE J. IDE, Registered Merit Reporter, certify that I was authorized to and did stenographically 6 report the proceedings herein, and that the transcript is a true and complete record of my stenographic notes. 7 I further certify that I am not a relative, 8 employee, attorney or counsel of any of the parties, nor am I a relative or employee of any of the parties' 9 attorney or counsel connected with the action, nor am I financially interested in the action. 10 11 DATED this 9th day of July, 2002. 12 13 14 ______________________________ LYNNE J. IDE, RMR 15 16 17 18 19 20 21 22 23 24 25